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Cristancho et al. v. SWBC Mortgage Corporation et al.

Court
S.D. Tex. (Galveston Div.)
Jurisdiction
USA
Decided
2026-08-04
AI tool
Implied
Outcome
Court identified and rejected fabricated citations (Pointe West and Tractebel), admonished counsel and reminded them of Rule 11 obligations; no professional sanction or monetary penalty imposed.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiffs cited Pointe West Center, LLC v. It's Alive, Inc., purportedly supporting a wrongful-initiation-of-foreclosure cause of action; the court found this cite to be fabricated. || Fabricated: Case Law | Plaintiffs relied on Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co. for a Restatement-based contract argument; the court determined the Tractebel opinion is fabricated.

Details

The court found that Plaintiffs' counsel cited fabricated authorities in their briefing (specifically Pointe West Center, LLC v. It's Alive, Inc. and Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co.), describing the submissions as containing fabricated quotations and assertions. The magistrate judge rejected those citations as fabricated, reminded counsel of their Rule 11 obligations, and relied on the absence of valid authority in granting summary judgment. No professional sanctions or monetary penalties were imposed in this decision.

Sanction teardown · S.D. Tex. (Galveston Div.), USA · 2026-08-04

Cristancho et al. v. SWBC Mortgage Corporation et al.

What happened

In S.D. Tex. (Galveston Div.), 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)
    Plaintiffs cited Pointe West Center, LLC v. It's Alive, Inc., purportedly supporting a wrongful-initiation-of-foreclosure cause of action; the court found this cite to be fabricated.
  • Fabricated (Case Law)
    Plaintiffs relied on Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co. for a Restatement-based contract argument; the court determined the Tractebel opinion is fabricated.

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

Court identified and rejected fabricated citations (Pointe West and Tractebel), admonished counsel and reminded them of Rule 11 obligations; no professional sanction or monetary penalty imposed.

Additional detail

The court found that Plaintiffs' counsel cited fabricated authorities in their briefing (specifically Pointe West Center, LLC v. It's Alive, Inc. and Tractebel Energy Marketing, Inc. v. E.I. Du Pont De Nemours & Co.), describing the submissions as containing fabricated quotations and assertions. The magistrate judge rejected those citations as fabricated, reminded counsel of their Rule 11 obligations, and relied on the absence of valid authority in granting summary judgment. No professional sanctions or monetary penalties were imposed in this decision.

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/2787/Cristancho_et_al_v._SWBC_Mortgage_Corporation_et_al_USA_4_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2787/Cristancho_et_al_v._SWBC_Mortgage_Corporation_et_al_USA_4_August_2026.pdf

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