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Erin Booker v. The Kroger Co.

Court
N.D. Georgia
Jurisdiction
USA
Decided
2026-08-28
AI tool
Unidentified
Outcome
Monetary Sanctions; CLE
Monetary penalty
8000 USD

What was hallucinated

Fabricated: Case Law | One of four cited authorities was determined to be a nonexistent case relied upon to support a legal proposition. || Fabricated: Case Law | A second highlighted authority was a fabricated case citation included in filings and cited for legal propositions. || Misrepresented: Case Law | A third authority was an existing case whose content was misrepresented or quoted inaccurately to support counsel's position. || Misrepresented: Case Law | A fourth authority consisted of misleading or false statements about the holdings of a real case authority.

Sanction teardown · N.D. Georgia, USA · 2026-08-28

Erin Booker v. The Kroger Co.

What happened

In N.D. Georgia, 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)
    One of four cited authorities was determined to be a nonexistent case relied upon to support a legal proposition.
  • Fabricated (Case Law)
    A second highlighted authority was a fabricated case citation included in filings and cited for legal propositions.
  • Misrepresented (Case Law)
    A third authority was an existing case whose content was misrepresented or quoted inaccurately to support counsel's position.
  • Misrepresented (Case Law)
    A fourth authority consisted of misleading or false statements about the holdings of a real case authority.

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

Monetary Sanctions; CLE (monetary penalty: 8000 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/3000/Booker_v._Kroger_USA_28_AUgust_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/3000/Booker_v._Kroger_USA_28_AUgust_2026.pdf

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