What was hallucinated

Misrepresented: Case Law | Plaintiff cited Cooter & Gell to support a heightened Rule 11 standard for civil rights cases; the court found Cooter is an antitrust case and does not support that proposition. || Fabricated: Case Law | Magistrate previously found counsel cited fictitious cases in response to Defendant Logan's motion; specific fabricated citations are not detailed in this order. || False Quotes: Case Law | Plaintiff quoted Dodd for the statement 'Rule 11 should not be used as a litigation tactic or to chill zealous advocacy,' which the court found nowhere in the Tenth Circuit opinion.

Sanction teardown · W.D. Oklahoma, USA · 2026-05-21

Dalton Gage Hill v. Oklahoma County Criminal Justice Authority (2)

What happened

In W.D. Oklahoma, 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)

Plaintiff cited Cooter & Gell to support a heightened Rule 11 standard for civil rights cases; the court found Cooter is an antitrust case and does not support that proposition.
Fabricated (Case Law)

Magistrate previously found counsel cited fictitious cases in response to Defendant Logan's motion; specific fabricated citations are not detailed in this order.
False Quotes (Case Law)

Plaintiff quoted Dodd for the statement 'Rule 11 should not be used as a litigation tactic or to chill zealous advocacy,' which the court found nowhere in the Tenth Circuit opinion.

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

Magistrate recommended sanctions

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/2175/Dalton_Gage_Hill_v._Oklahoma_County_Criminal_Justice_Authority_et_al._USA_21_May_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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