Sanction teardown · M.D. North Carolina, USA · 2026-04-28
Brandon Rulund Akins v. Tashi Latwon Ratliff, et al.
What happened
In M.D. North Carolina, 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:
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Fabricated (Case Law)Plaintiff cited two federal decisions with docket numbers and Westlaw citations that the court reports do not exist as cited.
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Fabricated (Case Law)Plaintiff cited a non-existent case at the given citation; court found the citation does not exist as cited.
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Fabricated (Case Law)Plaintiff relied on a cited North Carolina appellate case that the court found not to exist at the cited authority.
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Fabricated (Case Law)Plaintiff cited this state-court authority at an incorrect/nonexistent citation; court flagged it as inaccurate.
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Fabricated (Case Law)Federal case citation in plaintiff's filings does not exist at the cited report; court identified it as a fabricated or inaccurate citation.
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Fabricated (Case Law)Plaintiff cited an M.D.N.C. decision and citation that the court states does not exist at that citation.
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Fabricated (Case Law)Plaintiff referenced a case name without identifying information; court treated the unsupported citation as inaccurate.
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Fabricated (Case Law)Plaintiff asserted the existence of a 2024 North Carolina Supreme Court COVID-related decision supporting insurer liability; court found that characterization inaccurate and the cited authority incorrect.
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Fabricated (Case Law)Plaintiff relied on a docket citation and asserted procedural facts about that case (e.g., pro se amendment) that the court found inaccurate or unsupported by the cited docket.
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
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.
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Source: https://www.damiencharlotin.com/documents/2040/Akins_v._Ratliff_USA_28_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).