What was hallucinated

False Quotes: Case Law | Plaintiff attributed language to Walker v. City of Orem that does not appear in that decision; the brief quoted: "a district court must 'consider all pending motions and develop an adequate record' before dismissal." The court noted Walker contains no such language. || False Quotes: Case Law | Plaintiff attributed a proposition to United States v. Houston that the decision does not contain; the brief claimed: "failure to address pending motions constitutes procedural error." The court stated Houston contains no such proposition. || Fabricated: Case Law | Court observed the plaintiff had used multiple fabricated (nonexistent) cases in her filings (record citations at R. vol. 2 at 262–63) though the opinion does not list each fabricated citation.

Sanction teardown · 10th Cir. CA, USA · 2026-06-15

Chapter Kris Jackson v. Santander Consumer USA Inc., et al.

What happened

In 10th Cir. CA, 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 language to Walker v. City of Orem that does not appear in that decision; the brief quoted: "a district court must 'consider all pending motions and develop an adequate record' before dismissal." The court noted Walker contains no such language.
False Quotes (Case Law)

Plaintiff attributed a proposition to United States v. Houston that the decision does not contain; the brief claimed: "failure to address pending motions constitutes procedural error." The court stated Houston contains no such proposition.
Fabricated (Case Law)

Court observed the plaintiff had used multiple fabricated (nonexistent) cases in her filings (record citations at R. vol. 2 at 262–63) though the opinion does not list each fabricated citation.

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/2570/Jackson_v._Santander_USA_15_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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