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Boatner v. Hickerson

Court
CA Missouri
Jurisdiction
USA
Decided
2026-06-02
AI tool
Unidentified
Outcome
Monetary Sanction
Monetary penalty
10000 USD

What was hallucinated

Fabricated: Case Law | Appellant cited a non-existent case 'Davis v. Bess' in support of points; the Court found the citation fabricated and not cited in argument, undermining the brief's reliability. || Fabricated: Case Law | Appellant cited 'Jones v. Jones' which the Court determined to be fictitious and unsupported, contributing to the finding of fraud on the Court. || Fabricated: Case Law | Appellant relied on 'Kelley v. Kelley,' which the Court found does not exist as cited and was generated by A.I., impairing appellate review. || Fabricated: Case Law | Appellant referenced 'Stein v. Steeplechase Condominiums, Inc.,' another fictitious authority identified by the Court as A.I.-generated and not a valid precedent.

Sanction teardown · CA Missouri, USA · 2026-06-02

Boatner v. Hickerson

What happened

In CA Missouri, 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)
    Appellant cited a non-existent case 'Davis v. Bess' in support of points; the Court found the citation fabricated and not cited in argument, undermining the brief's reliability.
  • Fabricated (Case Law)
    Appellant cited 'Jones v. Jones' which the Court determined to be fictitious and unsupported, contributing to the finding of fraud on the Court.
  • Fabricated (Case Law)
    Appellant relied on 'Kelley v. Kelley,' which the Court found does not exist as cited and was generated by A.I., impairing appellate review.
  • Fabricated (Case Law)
    Appellant referenced 'Stein v. Steeplechase Condominiums, Inc.,' another fictitious authority identified by the Court as A.I.-generated and not a valid 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

Monetary Sanction (monetary penalty: 10000 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/2253/Boatner_v._Hickerson_USA_2_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2253/Boatner_v._Hickerson_USA_2_June_2026.pdf

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