What was hallucinated

Fabricated: Case Law | Counsel cited Matherne v. Cytec Corp., 78 F. App'x 977, 978 (5th Cir. 2003) as reversing a stay; the Court could not locate that opinion and research returned an unrelated Fifth Circuit decision (United States v. Strain). || Fabricated: Case Law | Counsel cited Von Drake v. Nat'l Sec. Agency, 156 F.3d 181, 1998 WL 546172, at *2 (5th Cir. 1998) for the proposition that an appellate court reversed a stay; the Court's searches did not locate such an opinion. || Misrepresented: Case Law | Counsel cited Fujita v. United States, 416 F. App'x 400, 402 (5th Cir. 2011) as affirming denial of a stay; the Court found the Fujita opinion actually affirmed the district court's grant of a stay and stated the stay was proper.

Details

In her latter response to the Court, Counsel apologised for her use of a "a non-firm approved general AI service".

Sanction teardown · S.D. Mississippi, USA · 2025-09-03

Blake Lewis v. Entergy Mississippi, LLC

What happened

In S.D. Mississippi, 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)

Counsel cited Matherne v. Cytec Corp., 78 F. App'x 977, 978 (5th Cir. 2003) as reversing a stay; the Court could not locate that opinion and research returned an unrelated Fifth Circuit decision (United States v. Strain).
Fabricated (Case Law)

Counsel cited Von Drake v. Nat'l Sec. Agency, 156 F.3d 181, 1998 WL 546172, at *2 (5th Cir. 1998) for the proposition that an appellate court reversed a stay; the Court's searches did not locate such an opinion.
Misrepresented (Case Law)

Counsel cited Fujita v. United States, 416 F. App'x 400, 402 (5th Cir. 2011) as affirming denial of a stay; the Court found the Fujita opinion actually affirmed the district court's grant of a stay and stated the stay was proper.

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

Order to show cause

Additional detail

In her latter response to the Court, Counsel apologised for her use of a "a non-firm approved general AI service".

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/826/Lewis_v_Entergy_Mississippi_LLC__mssdce-25-00323__0022.0.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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