Sanction teardown · D. Nevada, USA · 2026-03-31

Edward C. Allen v. Western Governors University, et al.

What happened

In D. Nevada, 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 attributed the quote "both baseless and made without a reasonable and competent inquiry" to Christian v. Mattel; court found no such quote in that opinion.
• False Quotes (Case Law)
  Plaintiff attributed the quote "a reasonable attorney in like circumstances could believe his actions to be factually and legally justified" to Cooter & Gell; court found no such quote in that Supreme Court opinion.
• Misrepresented (Case Law)
  Plaintiff attributed a leniency-for-pro-se quote to Warren v. Guelker, but the case contains no such quote and its holding is to the contrary; court found the attribution false.
• False Quotes (Case Law)
  Plaintiff attributed the quote "Rule 11 is not intended as a vehicle for intimidation or punishment for minor pleading errors" to Hudson; court found no such quote or holding in that opinion.
• False Quotes (Case Law)
  Plaintiff quoted the Supreme Court as cautioning against using Rule 11 "as a bar to the courthouse door" and cited Cooter & Gell at 393; court found no such quote in that opinion as used.
• Misrepresented (Case Law)
  Plaintiff cited Sineneng-Smith and claimed it "acknowledg[ed] appellate errata" in a cited footnote; court found no such reference and the footnote irrelevant to plaintiff's position.
• Fabricated (Case Law)
  Plaintiff cited "Verinata Health, Inc. v. Ariosa Diagnostics, Inc., 2014 WL 10321141, at *2 (N.D. Cal. Nov. 21, 2014)" to support that errata are accepted; court found the Westlaw number incorrect/misleading and no such supporting authority.
• Misrepresented (Case Law)
  Plaintiff cited Lewis v. Ryan (D. Ariz., Jan. 3, 2008) as accepting errata; court located a different Lewis v. Ryan under another number with no errata and found the representation false.

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

Case dismissed with prejudice; Adverse Costs Order (monetary penalty: 1 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/1886/Allen_v._Western_Governors_University_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).