Sanction teardown · SC New York, USA · 2026-01-08
Deutsche Bank National Bank v. Jean LeTennier
What happened
In SC New York, 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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Fabricated (Case Law)Submission of no less than 23 fabricated legal authorities across five filings, identified by plaintiff and confirmed by the court.
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Fabricated (Case Law)Example fabricated citation submitted as 'Tishman Realty & Construction Co. v. Regan' with a New York citation that does not correspond to any reported state or federal case.
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Misrepresented (Case Law)Misrepresentation of the holding of a real case—presented as dispositive for defendant when the cited case holds the opposite.
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
Orders affirmed; monetary sanctions imposed (counsel $5,000; defendant $2,500) and costs awarded (monetary penalty: 10000 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.
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Source: https://www.damiencharlotin.com/documents/1274/Deutsche_Bank_v._Le_Tennier_USA_8_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).