Sanction teardown · E.D. Louisiana, USA · 2026-03-20
Daniel Gentry v. Calvin Thompson et al.
What happened
In E.D. Louisiana, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Case Law)Second of nine case citations in Defendants' memorandum was nonexistent; Court noted unusual bullet-point formatting and counsel's failure to read the cited cases.
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Fabricated (Case Law)Third of nine case citations in Defendants' memorandum did not exist; Court concluded counsel relied on ChatGPT and did not verify the authority.
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Fabricated (Case Law)One of nine case citations in Defendants' memorandum did not exist as cited; Court found it was likely generated by ChatGPT and not checked by counsel.
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Fabricated (Case Law)Fourth of nine case citations in Defendants' memorandum was fabricated; the Court treated it as an AI-generated hallucination that went unchecked.
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Fabricated (Case Law)Fifth of nine case citations in Defendants' memorandum did not exist; counsel admitted using ChatGPT and failing to confirm the citations' validity.
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Fabricated (Case Law)Sixth of nine case citations in Defendants' memorandum was nonexistent; Court emphasized attorneys must read and verify every case they cite.
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Fabricated (Case Law)Seventh of nine case citations in Defendants' memorandum did not exist as cited; Court found objective Rule 11 violation based on failure to inquire.
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Fabricated (Case Law)Eighth of nine case citations in Defendants' memorandum was fabricated; Court noted supervisors bore responsibility for not noticing the hallucinations.
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Fabricated (Case Law)Ninth of nine case citations in Defendants' memorandum did not exist; Court determined the citations were likely produced by ChatGPT and unverified by counsel.
Which AI tool
ChatGPT. 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
Monetary sanction & formal admonishment (monetary penalty: 1250 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.
Check a brief before you file it → · See our live false-verify rate
Source: https://www.damiencharlotin.com/documents/1771/Gentry_v._Thompson_USA_20_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).