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Charlie Reyes v. Bryce Bailey, et al.

Court
D. New Mexico
Jurisdiction
USA
Decided
2026-08-28
AI tool
Implied
Outcome
No Sanctions
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff miscited (and may have fabricated) a case citation in his Amended Complaint; defendants reasonably alleged fabrication and court relied on plaintiff's admission.

Details

Plaintiff (pro se) admitted he miscited a case in his Amended Complaint. Defendants reasonably alleged the citation may have been fabricated. The Court found the defendants' contention reasonable given the plaintiff's admission, but declined to impose Rule 11 sanctions, concluding there was no violation and that other alleged defects did not warrant sanctions.

Sanction teardown · D. New Mexico, USA · 2026-08-28

Charlie Reyes v. Bryce Bailey, et al.

What happened

In D. New Mexico, 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)
    Plaintiff miscited (and may have fabricated) a case citation in his Amended Complaint; defendants reasonably alleged fabrication and court relied on plaintiff's admission.

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

No Sanctions

Additional detail

Plaintiff (pro se) admitted he miscited a case in his Amended Complaint. Defendants reasonably alleged the citation may have been fabricated. The Court found the defendants' contention reasonable given the plaintiff's admission, but declined to impose Rule 11 sanctions, concluding there was no violation and that other alleged defects did not warrant sanctions.

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/2996/Reyes_v._Bailey_USA_28_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2996/Reyes_v._Bailey_USA_28_August_2026.pdf

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