What was hallucinated

False Quotes: Case Law | Included at least 17 instances where quoted language did not match the cited sources (presented as direct quotes though not verbatim). || Fabricated: Case Law | Used substantive language in quotation marks that does not appear in the cited Supreme Court case.

Details

The Court found that attorney Tyrone A. Blackburn repeatedly used quotation marks for language that does not appear in the cases he cited (including at least 17 instances) and defended that practice as paraphrase. Opposing counsel (Roc Nation) flagged these apparent AI-generated citation errors, and the Court independently verified the quotations. Citing prior orders and sanctions (including a $5,000 sanction in Jakes v. Youngblood), the Court concluded Blackburn's conduct evidenced a pattern of fabricating quotations, granted the motion to strike his filing, deemed the sanctions motion unopposed, and referred Blackburn to the Grievance Committee. The Court emphasized the obligation to accurately quote and cite authority and noted refusal to accept paraphrases presented as verbatim quotations.

Sanction teardown · S.D. New York, USA · 2026-07-10

Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (2)

What happened

In S.D. New York, 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)

Included at least 17 instances where quoted language did not match the cited sources (presented as direct quotes though not verbatim).
Fabricated (Case Law)

Used substantive language in quotation marks that does not appear in the cited Supreme Court case.

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

Motion Struck; Bar Referral

Additional detail

The Court found that attorney Tyrone A. Blackburn repeatedly used quotation marks for language that does not appear in the cases he cited (including at least 17 instances) and defended that practice as paraphrase. Opposing counsel (Roc Nation) flagged these apparent AI-generated citation errors, and the Court independently verified the quotations. Citing prior orders and sanctions (including a $5,000 sanction in Jakes v. Youngblood), the Court concluded Blackburn's conduct evidenced a pattern of fabricating quotations, granted the motion to strike his filing, deemed the sanctions motion unopposed, and referred Blackburn to the Grievance Committee. The Court emphasized the obligation to accurately quote and cite authority and noted refusal to accept paraphrases presented as verbatim quotations.

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: http://reason.com/volokh/2026/07/10/lawyer-shows-complete-disregard-for-his-ethical-obligations-to-make-accurate-representations-to-the-court-magistrate-judge-says/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).