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Dewayne Clark v. CoreCivic

Court
W.D. Oklahoma
Jurisdiction
USA
Decided
2026-03-06
AI tool
Implied
Outcome
Admonishment
Monetary penalty
None reported

What was hallucinated

False Quotes: Case Law | Plaintiff quoted Garrison v. Gambro as stating summary judgment is a "drastic remedy" to be granted "with caution;" the court found Garrison does not contain that language or proposition. || False Quotes: Case Law | Plaintiff cited Tuckel v. Glover as recognizing unavailability where an inmate is "so sick" or incapacitated; the court found Tuckel does not include the quoted language or reflect that proposition. || Misrepresented: Case Law | Plaintiff's citation to Lemons v. Portfolio Recovery Assocs. in his Surreply was incorrect per the court (citation error/misrepresentation). || Fabricated: Case Law | Plaintiff cited Braham v. Cty. of Washington, No. 2:19-CV01128, 2020 WL 1166395, at *6, but the court could not locate any such case or citation, suggesting a fabricated citation. || Misrepresented: Case Law | Plaintiff cited Jones v. Bock for the proposition that the defendant bears the burden of proving availability of administrative remedies; the court noted Jones does not support that proposition.

Sanction teardown · W.D. Oklahoma, USA · 2026-03-06

Dewayne Clark v. CoreCivic

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:

  • False Quotes (Case Law)
    Plaintiff quoted Garrison v. Gambro as stating summary judgment is a "drastic remedy" to be granted "with caution;" the court found Garrison does not contain that language or proposition.
  • False Quotes (Case Law)
    Plaintiff cited Tuckel v. Glover as recognizing unavailability where an inmate is "so sick" or incapacitated; the court found Tuckel does not include the quoted language or reflect that proposition.
  • Misrepresented (Case Law)
    Plaintiff's citation to Lemons v. Portfolio Recovery Assocs. in his Surreply was incorrect per the court (citation error/misrepresentation).
  • Fabricated (Case Law)
    Plaintiff cited Braham v. Cty. of Washington, No. 2:19-CV01128, 2020 WL 1166395, at *6, but the court could not locate any such case or citation, suggesting a fabricated citation.
  • Misrepresented (Case Law)
    Plaintiff cited Jones v. Bock for the proposition that the defendant bears the burden of proving availability of administrative remedies; the court noted Jones does not support that proposition.

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

Admonishment

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/1646/Clark_v._Corecivic_USA_6_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1646/Clark_v._Corecivic_USA_6_March_2026.pdf

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