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Derence V. Fivehouse v. United States Department of Defense et al.

Court
E.D. North Carolina
Jurisdiction
USA
Decided
2026-03-02
AI tool
Implied
Outcome
Reprimand
Monetary penalty
None reported

What was hallucinated

Fabricated: Legal Norm | Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing summary judgment (D.E.90). || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Ohio Valley Environmental Coalition v. Aracoma Coal Co.; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: judicial notice (D.E.80). || Fabricated: Legal Norm | Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing preliminary injunction (D.E.39). || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Dow AgroSciences, LLC v. National Marine Fisheries Service; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Sierra Club v. United States Dept. of the Interior; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: Appellate Rule 16 (D.E.79).

Details

Show Cause Order is here; It was later reported that the prosecutor at stake resigned over the accident.

Sanction teardown · E.D. North Carolina, USA · 2026-03-02

Derence V. Fivehouse v. United States Department of Defense et al.

What happened

In E.D. North Carolina, 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 (Legal Norm)
    Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing summary judgment (D.E.90).
  • Fabricated (Case Law)
    Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Ohio Valley Environmental Coalition v. Aracoma Coal Co.; Renfer conceded incorrect citations.
  • Fabricated (Case Law)
    Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: judicial notice (D.E.80).
  • Fabricated (Legal Norm)
    Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing preliminary injunction (D.E.39).
  • Fabricated (Case Law)
    Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Dow AgroSciences, LLC v. National Marine Fisheries Service; Renfer conceded incorrect citations.
  • Fabricated (Case Law)
    Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Sierra Club v. United States Dept. of the Interior; Renfer conceded incorrect citations.
  • Fabricated (Case Law)
    Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: Appellate Rule 16 (D.E.79).

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

Reprimand

Additional detail

Show Cause Order is here; It was later reported that the prosecutor at stake resigned over the accident.

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/1601/gov.uscourts.nced.221403.119.0_1.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1601/gov.uscourts.nced.221403.119.0_1.pdf

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