What was hallucinated

Misrepresented: Case Law | Plaintiff cited Graves v. Smith's Transfer Corp., 736 F.2d 819, 820 (1st Cir. 1984) for a proposition the case does not hold; the Court found the case does not discuss the asserted point. || Outdated Advice: Overturned Case Law | Plaintiff relied on Scheuer v. Rhodes, 416 U.S. 232, 236 (1974) to state the old 'no set of facts' pleading standard, but the Court noted that the standard was retired by Bell Atlantic v. Twombly (2007). || Fabricated: Case Law | Plaintiff cited Phillips v. Phillips, 685 So. 2d 85 (Fla. 1st DCA 1996), but the Southern Second citation corresponds to Lowe Inv. Corp. v. Clemente, 685 So. 2d 84; the named Phillips opinion did not exist at that citation. || Fabricated: Case Law | Plaintiff cited Brydger v. Brydger, 910 So. 2d 381 (Fla. 4th DCA 2005), but the Southern Second citation corresponds to Whitley v. Royal Trails Prop. Owners' Ass'n, Inc., 910 So. 2d 381; the named Brydger citation was incorrect. || False Quotes: Case Law | Plaintiff attributed a specific quoted phrase to U.S. v. Int'l Brotherhood of Teamsters, 266 F.3d 45 (2d Cir. 2001), but the Court found no such quote in that opinion. || Fabricated: Case Law | Plaintiff cited a non-existent case captioned Ashley v. Bank of Am., 538 F. App'x 874; the cited Federal Appendix citation did not correspond to that caption. || Misrepresented: Case Law | Plaintiff cited an advisory opinion captioned In re Advisory Opinion to the Governor re: Dual Representation of State Officers, 630 So. 2d 1055 (Fla. 1994) and attributed holdings about the Attorney General that the opinion does not contain; the citation and summary were misleading.

Sanction teardown · M.D. Florida, USA · 2025-10-15

Charles C. Force v. Capital One, N.A., et al.

What happened

In M.D. Florida, 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:

Misrepresented (Case Law)

Plaintiff cited Graves v. Smith's Transfer Corp., 736 F.2d 819, 820 (1st Cir. 1984) for a proposition the case does not hold; the Court found the case does not discuss the asserted point.
Outdated Advice (Overturned Case Law)

Plaintiff relied on Scheuer v. Rhodes, 416 U.S. 232, 236 (1974) to state the old 'no set of facts' pleading standard, but the Court noted that the standard was retired by Bell Atlantic v. Twombly (2007).
Fabricated (Case Law)

Plaintiff cited Phillips v. Phillips, 685 So. 2d 85 (Fla. 1st DCA 1996), but the Southern Second citation corresponds to Lowe Inv. Corp. v. Clemente, 685 So. 2d 84; the named Phillips opinion did not exist at that citation.
Fabricated (Case Law)

Plaintiff cited Brydger v. Brydger, 910 So. 2d 381 (Fla. 4th DCA 2005), but the Southern Second citation corresponds to Whitley v. Royal Trails Prop. Owners' Ass'n, Inc., 910 So. 2d 381; the named Brydger citation was incorrect.
False Quotes (Case Law)

Plaintiff attributed a specific quoted phrase to U.S. v. Int'l Brotherhood of Teamsters, 266 F.3d 45 (2d Cir. 2001), but the Court found no such quote in that opinion.
Fabricated (Case Law)

Plaintiff cited a non-existent case captioned Ashley v. Bank of Am., 538 F. App'x 874; the cited Federal Appendix citation did not correspond to that caption.
Misrepresented (Case Law)

Plaintiff cited an advisory opinion captioned In re Advisory Opinion to the Governor re: Dual Representation of State Officers, 630 So. 2d 1055 (Fla. 1994) and attributed holdings about the Attorney General that the opinion does not contain; the citation and summary were misleading.

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

Filings stricken; Show Cause Order

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/875/Force_v._Capital_One_USA_15_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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