What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Dvorak v. Metropolitan Pier & Exposition Authority, 941 F.3d 936 (7th Cir. 2019)', which the court (as defendants pointed out) appears not to exist; court flagged this as an AI-style fabricated citation. || False Quotes: Case Law | Plaintiff attributed a quotation to Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) that does not exist in that opinion; court identified this as a false quotation. || Misrepresented: Case Law | Plaintiff cited LeBeau v. Taco Bell, Inc., 892 F.2d 605 (7th Cir. 1989) as supporting the two-dismissal rule, but the court found the opinion does not discuss that rule (misrepresented precedent).

Sanction teardown · N.D. Illinois, USA · 2026-02-09

Bettis v. Gaston

What happened

In N.D. Illinois, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Plaintiff cited 'Dvorak v. Metropolitan Pier & Exposition Authority, 941 F.3d 936 (7th Cir. 2019)', which the court (as defendants pointed out) appears not to exist; court flagged this as an AI-style fabricated citation.
False Quotes (Case Law)

Plaintiff attributed a quotation to Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) that does not exist in that opinion; court identified this as a false quotation.
Misrepresented (Case Law)

Plaintiff cited LeBeau v. Taco Bell, Inc., 892 F.2d 605 (7th Cir. 1989) as supporting the two-dismissal rule, but the court found the opinion does not discuss that rule (misrepresented precedent).

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Warning

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/1497/Robert_Bettis_Plaintiff_v_Sabrina_Gaston_Evelyn_Smith_Sarah_Melgarejo_Cath.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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