What was hallucinated

Misrepresented: Case Law | Cited Avery v. State Farm, 216 Ill. 2d 100 (2005) for the proposition that Consumer Fraud Act damages claims are legal claims triable to a jury; court found Avery contains no support for that proposition. || Misrepresented: Case Law | Cited People ex rel. Daley v. Datacom Systems Corp., 146 Ill. 2d 1 (1991) as supporting that joined legal and equitable issues require the legal issues be tried to a jury; court found Datacom contains no support for that proposition. || Misrepresented: Case Law | Cited 'Stephens v. Kasten, 334 Ill. App. 3d 1004,' a citation the court found does not correspond to Stephens (which is Stephens v. Kasten, 383 Ill. 127) and the cited volume/page correspond to a different case (People v. Lewis). || Misrepresented: Case Law | Cited 'In re Estate of Mulvaney, 288 Ill. App. 3d 464,' but the court noted Mulvaney actually begins at 128 Ill. App. 3d 133 and the cited reporter/page corresponds to People v. Lambert. || Misrepresented: Case Law | Cited 'Kaiser v. MEPC American Properties, Inc., 164 Ill. 2d 274' with an incorrect citation/attribution as noted by the court among other miscited authorities. || Misrepresented: Case Law | Cited 'Harris Trust & Savings Bank v. Chicago College of Osteopathic Medicine, 116 Ill. 2d 145' with an incorrect citation/attribution; court treated this as one of multiple inaccurate citations.

Sanction teardown · CA Illinois, USA · 2026-07-30

Cole v. Lee

What happened

In CA Illinois, 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)

Cited Avery v. State Farm, 216 Ill. 2d 100 (2005) for the proposition that Consumer Fraud Act damages claims are legal claims triable to a jury; court found Avery contains no support for that proposition.
Misrepresented (Case Law)

Cited People ex rel. Daley v. Datacom Systems Corp., 146 Ill. 2d 1 (1991) as supporting that joined legal and equitable issues require the legal issues be tried to a jury; court found Datacom contains no support for that proposition.
Misrepresented (Case Law)

Cited 'Stephens v. Kasten, 334 Ill. App. 3d 1004,' a citation the court found does not correspond to Stephens (which is Stephens v. Kasten, 383 Ill. 127) and the cited volume/page correspond to a different case (People v. Lewis).
Misrepresented (Case Law)

Cited 'In re Estate of Mulvaney, 288 Ill. App. 3d 464,' but the court noted Mulvaney actually begins at 128 Ill. App. 3d 133 and the cited reporter/page corresponds to People v. Lambert.
Misrepresented (Case Law)

Cited 'Kaiser v. MEPC American Properties, Inc., 164 Ill. 2d 274' with an incorrect citation/attribution as noted by the court among other miscited authorities.
Misrepresented (Case Law)

Cited 'Harris Trust & Savings Bank v. Chicago College of Osteopathic Medicine, 116 Ill. 2d 145' with an incorrect citation/attribution; court treated this as one of multiple inaccurate citations.

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

Brief struck

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/2758/Cole_v._Lee_2026_IL_App_1st_252223-U.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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