What was hallucinated

Fabricated: Case Law | Plaintiffs cited “Jarrod Johnson v. Water Light & Sinking Fund Comm’n…, 74 F.4th 1308, 1313–17 (11th Cir. 2023)” for PFAS-standing language; court found the citation led to unrelated authority and the claimed PFAS discussion does not exist. || False Quotes: Case Law | Plaintiffs quoted Gonsalvez but the court identified the passage as a misquote/false quote that did not match the actual language of Gonsalvez v. Celebrity Cruises. || False Quotes: Case Law | Plaintiffs attributed a shortened/altered quotation to Ex parte Abbott Laboratories that materially differed from the actual opinion. || False Quotes: Case Law | Plaintiffs quoted Ex parte McKesson Corporation in a way that the court identified as an inaccurate or edited quotation not matching the opinion's actual language. || Misrepresented: Case Law | Plaintiffs relied on Cook v. Randolph Cty., 573 F.3d 1143, 1150-51 (11th Cir. 2009) to support a Rule 15 amendment entitlement, but Cook concerned remand and summary judgment—not Rule 15 amendment standards; the case was misread/misapplied. || Misrepresented: Case Law | Plaintiffs cited Payton v. Monsanto, 801 So. 2d 829, 835-36 (Ala. 2001) claiming it supported a discovery rule for accrual; the court noted Payton actually rejects such a discovery rule—Plaintiffs mischaracterized the holding. || Misrepresented: Case Law | Plaintiffs described Southern Bakeries/Knipp as involving a union boycott and not exposure; the court found that characterization incorrect and noted the pinpoint cite spans into a concurrence, making Plaintiffs' use erroneous. || Fabricated: Case Law | Plaintiffs cited “Adams v. 3M Co., 67 F.4th 845, 853-55 (6th Cir. 2023)” attributing PFAS findings; court could not find that opinion at that citation and the real Adams decision did not contain the alleged language.

Sanction teardown · N.D. Alabama, USA · 2026-04-20

Bridgett Watson Adams, et al. v. 3M Company

What happened

In N.D. Alabama, 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)

Plaintiffs cited “Jarrod Johnson v. Water Light & Sinking Fund Comm’n…, 74 F.4th 1308, 1313–17 (11th Cir. 2023)” for PFAS-standing language; court found the citation led to unrelated authority and the claimed PFAS discussion does not exist.
False Quotes (Case Law)

Plaintiffs quoted Gonsalvez but the court identified the passage as a misquote/false quote that did not match the actual language of Gonsalvez v. Celebrity Cruises.
False Quotes (Case Law)

Plaintiffs attributed a shortened/altered quotation to Ex parte Abbott Laboratories that materially differed from the actual opinion.
False Quotes (Case Law)

Plaintiffs quoted Ex parte McKesson Corporation in a way that the court identified as an inaccurate or edited quotation not matching the opinion's actual language.
Misrepresented (Case Law)

Plaintiffs relied on Cook v. Randolph Cty., 573 F.3d 1143, 1150-51 (11th Cir. 2009) to support a Rule 15 amendment entitlement, but Cook concerned remand and summary judgment—not Rule 15 amendment standards; the case was misread/misapplied.
Misrepresented (Case Law)

Plaintiffs cited Payton v. Monsanto, 801 So. 2d 829, 835-36 (Ala. 2001) claiming it supported a discovery rule for accrual; the court noted Payton actually rejects such a discovery rule—Plaintiffs mischaracterized the holding.
Misrepresented (Case Law)

Plaintiffs described Southern Bakeries/Knipp as involving a union boycott and not exposure; the court found that characterization incorrect and noted the pinpoint cite spans into a concurrence, making Plaintiffs' use erroneous.
Fabricated (Case Law)

Plaintiffs cited “Adams v. 3M Co., 67 F.4th 845, 853-55 (6th Cir. 2023)” attributing PFAS findings; court could not find that opinion at that citation and the real Adams decision did not contain the alleged language.

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

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/2577/Adams_-_43.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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