What was hallucinated

Fabricated: Case Law | Respondent cited 'Nationwide Mutual Insurance Co. v. Jackson' in his opening brief; the panel determined the opinion does not exist and that respondent later said he meant to cite Darden but omitted that argument in a revised brief. || Fabricated: Case Law | Respondent cited 'Commodity Futures Trading Commission v. Glencore Ltd.' in his reply brief; the panel found no such published appellate opinion and respondent later supplied an unrelated CFTC administrative proceeding. || Fabricated: Case Law | Respondent cited 'In re Acres Properties, Inc.' in his reply brief; the panel found that citation to be nonexistent and that the cases respondent said he meant to cite were different and of minimal relevance.

Sanction teardown · CA Fourth Circuit, USA · 2026-03-11

Bolden v. Baltimore Gas & Electric Co (In re: Eric Chibueze Nwaubani)

What happened

In CA Fourth Circuit, 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)

Respondent cited 'Nationwide Mutual Insurance Co. v. Jackson' in his opening brief; the panel determined the opinion does not exist and that respondent later said he meant to cite Darden but omitted that argument in a revised brief.
Fabricated (Case Law)

Respondent cited 'Commodity Futures Trading Commission v. Glencore Ltd.' in his reply brief; the panel found no such published appellate opinion and respondent later supplied an unrelated CFTC administrative proceeding.
Fabricated (Case Law)

Respondent cited 'In re Acres Properties, Inc.' in his reply brief; the panel found that citation to be nonexistent and that the cases respondent said he meant to cite were different and of minimal relevance.

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

Public admonishment

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://reason.com/volokh/2026/03/12/fourth-circuit-publicly-admonishes-lawyer-for-citations-to-nonexistent-judicial-opinions/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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