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BKA Holdings v. Sam

Court
CA Illinois
Jurisdiction
USA
Decided
2025-09-16
AI tool
Implied
Outcome
Plaintiff awarded attorney fees and costs for spotting hallucinated authority
Monetary penalty
1 USD

What was hallucinated

Fabricated: Case Law | A third cited authority in the reply brief was AI-generated and non-existent; the court treated the repeated reliance on fabricated cases as abusive use of AI and struck the brief. || Fabricated: Case Law | A fourth AI-generated case citation was included in the reply brief; the court noted four hallucinated cases and granted plaintiff's sanctions motion. || Fabricated: Case Law | Defendants' reply brief cited an AI-generated, non-existent case; the court found the authority hallucinated and struck the reply brief as part of granting sanctions. || Fabricated: Case Law | A second AI-generated case citation appeared in defendants' reply brief; the court identified it as hallucinated and relied on the existence of multiple fabricated cases in granting sanctions.

Sanction teardown · CA Illinois, USA · 2025-09-16

BKA Holdings v. Sam

What happened

In CA 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)
    A third cited authority in the reply brief was AI-generated and non-existent; the court treated the repeated reliance on fabricated cases as abusive use of AI and struck the brief.
  • Fabricated (Case Law)
    A fourth AI-generated case citation was included in the reply brief; the court noted four hallucinated cases and granted plaintiff's sanctions motion.
  • Fabricated (Case Law)
    Defendants' reply brief cited an AI-generated, non-existent case; the court found the authority hallucinated and struck the reply brief as part of granting sanctions.
  • Fabricated (Case Law)
    A second AI-generated case citation appeared in defendants' reply brief; the court identified it as hallucinated and relied on the existence of multiple fabricated cases in granting sanctions.

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

Plaintiff awarded attorney fees and costs for spotting hallucinated authority (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.

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Source: https://www.damiencharlotin.com/documents/794/BKA_Holdings_v._Sam_2025_IL_App_2d_250160-U.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/794/BKA_Holdings_v._Sam_2025_IL_App_2d_250160-U.pdf

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