What was hallucinated

Fabricated: Case Law | Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation. || Fabricated: Case Law | Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation. || Fabricated: Case Law | Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation.

Details

" Moreover, we take this opportunity to caution practitioners of this Commonwealth on the submission of briefs or citations without confirming their accuracy and the correctness of the resulting analysis. The abject failure to conduct due diligence when making arguments to the Court greatly impacts the profession and undermines confidence in the skills and knowledge necessary to practice as an attorney. Failure to verify substantive legal citations prior to submission to this Court is not only in derogation of the RAP, but also violates the attorney's ethical responsibilities. See Supreme Court Rule 3.130(1.1).Mistakes occur. Oversights happen. Those types of inadvertent errors we could absolve. However, purposelessly submitting a brief to a Court of law without confirming that the cited case law even exists is an affront to the dignity of the Court system, the legal profession as a whole, the judiciary, the client, and the public at large."

Sanction teardown · CA Kentucky, USA · 2025-10-24

Crowder v. Yussman

What happened

In CA Kentucky, 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)

Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation.
Fabricated (Case Law)

Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation.
Fabricated (Case Law)

Appellant brief cited a nonexistent case as precedent; Court and appellee identified it as fabricated and counsel admitted it was a placeholder citation.

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

Warning

Additional detail

" Moreover, we take this opportunity to caution practitioners of this Commonwealth on the submission of briefs or citations without confirming their accuracy and the correctness of the resulting analysis. The abject failure to conduct due diligence when making arguments to the Court greatly impacts the profession and undermines confidence in the skills and knowledge necessary to practice as an attorney. Failure to verify substantive legal citations prior to submission to this Court is not only in derogation of the RAP, but also violates the attorney's ethical responsibilities. See Supreme Court Rule 3.130(1.1).Mistakes occur. Oversights happen. Those types of inadvertent errors we could absolve. However, purposelessly submitting a brief to a Court of law without confirming that the cited case law even exists is an affront to the dignity of the Court system, the legal profession as a whole, the judiciary, the client, and the public at large."

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/968/Crowder_v._Yussman_USA_24_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).