What was hallucinated

Fabricated: Case Law | Petitioner cited 'Santos v. Warden Allenwood FCI, No. 1:17-CV-02116, 2018 WL 1178251 (M.D. Pa. Mar. 6, 2018)'; court found no such M.D. Pa. decision — the 2018 WL number corresponds to Certain Underwriters at Lloyd's, London v. Pettit (W.D. Wash.), unrelated to petitioner's claim. || Fabricated: Case Law | Petitioner cited 'Rodriguez v. Ebbert, No. 3:14-CV-02404, 2015 WL 1810315 (M.D. Pa. Apr. 21, 2015)'; court found 2015 WL 1810315 corresponds to an unrelated Florida appellate decision (D.S. v. Dep't of Child. & Fams.), not the cited M.D. Pa. case. || Fabricated: Case Law | Petitioner cited 'Cruz v. United States, No. 1:16-CV-01034, 2016 WL 8732312 (M.D. Pa. Dec. 16, 2016)'; court found 2016 WL 8732312 corresponds to Black Water Mgmt., LLC v. Sprenkle (E.D. Va.), not the cited M.D. Pa. decision. || Misrepresented: Case Law | When using this court's docket numbers, petitioner identified cases (e.g., Firestone v. Rockovich, No. 1:17-CV-2116; Fagal v. Marywood Univ.; Drake v. Warden of Allenwood Low) that exist but are irrelevant to his claim — the court treated these as misattributed and not supportive of petitioner's position.

Sanction teardown · M.D. Pennsylvania, USA · 2026-03-16

Domingo Beato-Estrella v. M. Arviza

What happened

In M.D. Pennsylvania, 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 (Case Law)

Petitioner cited 'Santos v. Warden Allenwood FCI, No. 1:17-CV-02116, 2018 WL 1178251 (M.D. Pa. Mar. 6, 2018)'; court found no such M.D. Pa. decision — the 2018 WL number corresponds to Certain Underwriters at Lloyd's, London v. Pettit (W.D. Wash.), unrelated to petitioner's claim.
Fabricated (Case Law)

Petitioner cited 'Rodriguez v. Ebbert, No. 3:14-CV-02404, 2015 WL 1810315 (M.D. Pa. Apr. 21, 2015)'; court found 2015 WL 1810315 corresponds to an unrelated Florida appellate decision (D.S. v. Dep't of Child. & Fams.), not the cited M.D. Pa. case.
Fabricated (Case Law)

Petitioner cited 'Cruz v. United States, No. 1:16-CV-01034, 2016 WL 8732312 (M.D. Pa. Dec. 16, 2016)'; court found 2016 WL 8732312 corresponds to Black Water Mgmt., LLC v. Sprenkle (E.D. Va.), not the cited M.D. Pa. decision.
Misrepresented (Case Law)

When using this court's docket numbers, petitioner identified cases (e.g., Firestone v. Rockovich, No. 1:17-CV-2116; Fagal v. Marywood Univ.; Drake v. Warden of Allenwood Low) that exist but are irrelevant to his claim — the court treated these as misattributed and not supportive of petitioner's position.

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/1694/Beato_Estrella_v._Swaney_USA_16_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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