What was hallucinated

Fabricated: Case Law | Plaintiff cited Perez v. Miami-Dade Cnty., 297 F.R.D. 620, 625 (S.D. Fla. 2013) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent. || Fabricated: Case Law | Plaintiff cited Jacobs v. Atrium Med. Corp., 2020 WL 5803503, at *2-3 (S.D. Fla. Sept. 29, 2020) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent. || False Quotes: Case Law | Plaintiff quoted Universal City Dev. Partners, Ltd. v. Ride & Show, 230 F.R.D. 688, 695 (M.D. Fla. 2005) as saying “is tantamount to no objection at all.” (DE 78 at 2); the Court found no such quote exists in that case.

Details

In the case of Crespo v. Tesla, Inc., the pro se plaintiff, Leonardo Crespo, submitted discovery motions containing fabricated case citations and a false quote, which were identified as potentially generated by AI. The court ordered Crespo to show cause for these submissions and admitted to using AI in his filings. The court acknowledged Crespo's candor and imposed sanctions requiring him to apologize to the defendant's counsel and pay reasonable attorney's fees incurred by the defendant in addressing the fake citations.(In a subsequent ruling, the court averred that the reasonable fees amount was 921 USD.)

Sanction teardown · S.D. Florida, USA · 2025-06-30

Crespo v. Tesla, Inc.

What happened

In S.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:

Fabricated (Case Law)

Plaintiff cited Perez v. Miami-Dade Cnty., 297 F.R.D. 620, 625 (S.D. Fla. 2013) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent.
Fabricated (Case Law)

Plaintiff cited Jacobs v. Atrium Med. Corp., 2020 WL 5803503, at *2-3 (S.D. Fla. Sept. 29, 2020) in DEs 61, 63, 78, 79, 80; the Court found this case appears nonexistent.
False Quotes (Case Law)

Plaintiff quoted Universal City Dev. Partners, Ltd. v. Ride & Show, 230 F.R.D. 688, 695 (M.D. Fla. 2005) as saying “is tantamount to no objection at all.” (DE 78 at 2); the Court found no such quote exists in that case.

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

Plaintiff required to apologize and pay attorney's fees (monetary penalty: 921 USD.)

Additional detail

In the case of Crespo v. Tesla, Inc., the pro se plaintiff, Leonardo Crespo, submitted discovery motions containing fabricated case citations and a false quote, which were identified as potentially generated by AI. The court ordered Crespo to show cause for these submissions and admitted to using AI in his filings. The court acknowledged Crespo's candor and imposed sanctions requiring him to apologize to the defendant's counsel and pay reasonable attorney's fees incurred by the defendant in addressing the fake citations.(In a subsequent ruling, the court averred that the reasonable fees amount was 921 USD.)

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/557/Crespo_v._Tesla_USA_30_June_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).