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Cotto v. United States

Court
D. Colorado
Jurisdiction
USA
Decided
2025-11-17
AI tool
Implied
Outcome
Motion for reconsideration denied; court identified the cited case/citation as nonexistent/miscited and rejected reliance on it.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Ayala v. Holmes, 29 F.4th 1015' for summary-judgment guidance; the Court found no such decision exists, noted the 29 F.4th pin cite aligns with Barrera Arreguin v. Garland, 29 F.4th 1010, and that an unrelated Ayala v. Holmes, 29 F. App'x 548 (10th Cir. 2002) exists.

Sanction teardown · D. Colorado, USA · 2025-11-17

Cotto v. United States

What happened

In D. Colorado, 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 cited 'Ayala v. Holmes, 29 F.4th 1015' for summary-judgment guidance; the Court found no such decision exists, noted the 29 F.4th pin cite aligns with Barrera Arreguin v. Garland, 29 F.4th 1010, and that an unrelated Ayala v. Holmes, 29 F. App'x 548 (10th Cir. 2002) exists.

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 for reconsideration denied; court identified the cited case/citation as nonexistent/miscited and rejected reliance on it.

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/1061/Cotto_v._USA_USA_17_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1061/Cotto_v._USA_USA_17_November_2025.pdf

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