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BKA Holdings, LLC v. Sam

Court
CA Illinois (2d)
Jurisdiction
USA
Decided
2025-09-16
AI tool
Unidentified
Outcome
Reply brief stricken; Adverse Costs Order
Monetary penalty
1 USD

What was hallucinated

Fabricated: Case Law | The defendants relied on four cases that the court identified as hallucinated by artificial intelligence. The court did not name or analyze the individual citations in the order. || Fabricated: Case Law | The defendants cited four cases in their reply brief that were hallucinated by AI; the opinion does not identify the fabricated case names or citations individually. The court treated the citations as nonexistent authority and sanctioned the defendants by striking the reply brief.

Sanction teardown · CA Illinois (2d), USA · 2025-09-16

BKA Holdings, LLC v. Sam

What happened

In CA Illinois (2d), 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)
    The defendants relied on four cases that the court identified as hallucinated by artificial intelligence. The court did not name or analyze the individual citations in the order.
  • Fabricated (Case Law)
    The defendants cited four cases in their reply brief that were hallucinated by AI; the opinion does not identify the fabricated case names or citations individually. The court treated the citations as nonexistent authority and sanctioned the defendants by striking the reply brief.

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

Reply brief stricken; Adverse Costs Order (monetary penalty: 1 USD.)

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3124/BKA_Holdings_v_jetzDGM._Sam_USA_16_Septmeber_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/3124/BKA_Holdings_v_jetzDGM._Sam_USA_16_Septmeber_2026.pdf

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