What was hallucinated

False Quotes: Case Law | Plaintiff attributed a wholly fabricated quotation to this real case. || Misrepresented: Case Law | Case cited to support Eighth Amendment application to probationers though Solem concerned incarceration and is not relevant here. || Misrepresented: Case Law | Cited to support Eighth Amendment argument despite Graham involving incarceration rather than probation. || False Quotes: Case Law | Plaintiff misattributed a quotation to Moore and cited it in support of an Eighth Amendment argument though Moore addresses a Fourth Amendment apartment-search context. || Misrepresented: Case Law | Cited Rochin to support an Eighth Amendment 'shocks the conscience' argument though Rochin concerns due process (Thirteenth and Fourteenth Amendments) and is not on point. || Misrepresented: Case Law | Plaintiff relied on Steffel but that case addresses First and Fourteenth Amendment issues, not the Eighth. || Misrepresented: Case Law | Misstated the holding; Jones concerns GPS attachment to a vehicle, not to a person as plaintiff asserted. || Misrepresented: Case Law | Cited Hamilton for a sovereign-immunity point but failed to note Hamilton dismissed negligence claims as barred by sovereign immunity. || Fabricated: Case Law | Entirely fabricated case; plaintiff supplied a citation string that corresponds to different cases with different names. || Misrepresented: Case Law | Cited Fuller to suggest probationers have Eighth Amendment protections relevant here, but the case concerns prison housing classification and is not on point. || Fabricated: Case Law | Entirely fabricated case; the plaintiff cited 'State v. Kelleher' with citations that lead to unrelated real cases. || Outdated Advice: Overturned Case Law | Cited Quon without disclosing that the Ninth Circuit decision was explicitly reversed and remanded by the Supreme Court.

Sanction teardown · D. Connecticut, USA · 2025-12-15

Braica v. Frankowski (Anthony Braica v. Tom Frankowski)

What happened

In D. Connecticut, 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:

False Quotes (Case Law)

Plaintiff attributed a wholly fabricated quotation to this real case.
Misrepresented (Case Law)

Case cited to support Eighth Amendment application to probationers though Solem concerned incarceration and is not relevant here.
Misrepresented (Case Law)

Cited to support Eighth Amendment argument despite Graham involving incarceration rather than probation.
False Quotes (Case Law)

Plaintiff misattributed a quotation to Moore and cited it in support of an Eighth Amendment argument though Moore addresses a Fourth Amendment apartment-search context.
Misrepresented (Case Law)

Cited Rochin to support an Eighth Amendment 'shocks the conscience' argument though Rochin concerns due process (Thirteenth and Fourteenth Amendments) and is not on point.
Misrepresented (Case Law)

Plaintiff relied on Steffel but that case addresses First and Fourteenth Amendment issues, not the Eighth.
Misrepresented (Case Law)

Misstated the holding; Jones concerns GPS attachment to a vehicle, not to a person as plaintiff asserted.
Misrepresented (Case Law)

Cited Hamilton for a sovereign-immunity point but failed to note Hamilton dismissed negligence claims as barred by sovereign immunity.
Fabricated (Case Law)

Entirely fabricated case; plaintiff supplied a citation string that corresponds to different cases with different names.
Misrepresented (Case Law)

Cited Fuller to suggest probationers have Eighth Amendment protections relevant here, but the case concerns prison housing classification and is not on point.
Fabricated (Case Law)

Entirely fabricated case; the plaintiff cited 'State v. Kelleher' with citations that lead to unrelated real cases.
Outdated Advice (Overturned Case Law)

Cited Quon without disclosing that the Ninth Circuit decision was explicitly reversed and remanded by the Supreme Court.

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

Briefs struck; warning

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/1198/Braica_v._Frankowski_USA_15_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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