What was hallucinated

Misrepresented: Case Law | Plaintiff cited Harris v. One Hope United, Inc., 28 N.E.3d 804 (Ill. 2015) for the proposition that parent and subsidiary may be treated as a single entity, but the case concerns discovery privilege and does not support that corporate-law proposition (misapplied precedent). || Fabricated: Case Law | Plaintiff repeatedly cited 'Heritage Common Partners v. Village of Summit' with 2009 Illinois reporter citations that the court could not locate; court found no Illinois case by that name and the only reported federal opinions by that name were from 1990–1991 and unrelated to the cited propositions.

Sanction teardown · N.D. Illinois, USA · 2026-03-31

Ella and Ramin LLC v. Travelers Insurance Company

What happened

In N.D. Illinois, 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:

Misrepresented (Case Law)

Plaintiff cited Harris v. One Hope United, Inc., 28 N.E.3d 804 (Ill. 2015) for the proposition that parent and subsidiary may be treated as a single entity, but the case concerns discovery privilege and does not support that corporate-law proposition (misapplied precedent).
Fabricated (Case Law)

Plaintiff repeatedly cited 'Heritage Common Partners v. Village of Summit' with 2009 Illinois reporter citations that the court could not locate; court found no Illinois case by that name and the only reported federal opinions by that name were from 1990–1991 and unrelated to the cited propositions.

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

Not specified in source record.

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/1928/ELLA_AND_RAMIN_LLC_Plaintiff_v_TRAVELERS_INSURANCE_COMPANY_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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