Sanction teardown · W.D. Washington, USA · 2026-01-29
Dana Serine Greene v. GSK PLC
What happened
In W.D. Washington, 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:
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Misrepresented (Case Law)Plaintiff cited Brockmeyer v. May but the authority does not support the proposition or contain the quoted text; court identified it among inaccurate/misused citations.
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Misrepresented (Case Law)Plaintiff cited Freedom Watch, Inc. v. OPEC but the opinion does not contain the text she quotes; court listed it as an inaccurate citation.
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Misrepresented (Case Law)Plaintiff cited Porsche Cars N. Am., Inc. v. Porsche.net and allegedly misquoted or misapplied its text; court flagged it as not supporting her proposition.
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Misrepresented (Case Law)Plaintiff cited Gurung v. Malhotra but the text cited is not present in that authority; court included it among suspect citations.
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Misrepresented (Case Law)Plaintiff cited In re LLS Am., LLC but the court found the citation did not support her quoted text and listed it among problematic citations.
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Fabricated (Case Law)The opinion contains multiple citation references that are incorrect or do not actually exist; Editor's Note preserves these invalid citations as part of the record.
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
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/1431/DANA_SERINE_GREENE_Plaintiff_v_GSK_PLC_fka_GlaxoSmithKline_Defendant.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).