What was hallucinated

False Quotes: Case Law | Quotation attributed to 'Bonin v. Chadron Community Hospital, 28 F.4th at 1039-40' not found in that order; true case appears to be Bonin v. Chadron Community Hospital, 163 F.R.D. 656 (D. Neb. 1995), and the quoted language does not appear there. || False Quotes: Case Law | Citation 'Watson v. Argee Transportation Co., 378 F.3d 993, 999 (8th Cir. 2004)' is incorrect; the correct case is Watson v. Argee Transport Co., No. 4:23-CV-00722-NCC, 2024 WL 1514294 (E.D. Mo. Apr. 5, 2024), and the quoted language does not appear in the correctly cited opinion. || Fabricated: Case Law | Citation 'Rodriguez v. United States, 823 F.3d 593, 600-01 (8th Cir. 2016)' appears not to exist and misreferences 823 F.3d 593 (which is an 11th Cir. decision, Foudy v. Miami-Dade County); the Court could not locate the cited Eighth Circuit case. || Misrepresented: Case Law | Case cited as 'Earth to Go v. Midwest Coal, 682 S.W.3d 424 (Mo. App. 2024)' is incorrect; the correct citation is Earth to Go v. City of Richland, 706 S.W.3d 310 (Mo. Ct. App. 2025). || False Quotes: Case Law | Quotations attributed to Harvey v. Timber Resources, 37 S.W.3d 814, 818 (Mo. Ct. App. 2001) were not found in Harvey and instead appear in BMK Corp. v. Clayton Corp., 226 S.W.3d 179, 195 (Mo. Ct. App. 2007). || Misrepresented: Case Law | Multiple federal and district opinions (e.g., Consultus orders, Kudabeck, Wagner, Vanderberg, Wegener, Marmo) were cited as supporting Rule 37(c)(1) propositions when they involved Daubert challenges or different issues and do not support the asserted propositions.

Sanction teardown · W.D. Missouri, USA · 2026-06-22

Euphoric, LLC et al. v. Westport Community Improvement District, et al. (2)

What happened

In W.D. Missouri, 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)

Quotation attributed to 'Bonin v. Chadron Community Hospital, 28 F.4th at 1039-40' not found in that order; true case appears to be Bonin v. Chadron Community Hospital, 163 F.R.D. 656 (D. Neb. 1995), and the quoted language does not appear there.
False Quotes (Case Law)

Citation 'Watson v. Argee Transportation Co., 378 F.3d 993, 999 (8th Cir. 2004)' is incorrect; the correct case is Watson v. Argee Transport Co., No. 4:23-CV-00722-NCC, 2024 WL 1514294 (E.D. Mo. Apr. 5, 2024), and the quoted language does not appear in the correctly cited opinion.
Fabricated (Case Law)

Citation 'Rodriguez v. United States, 823 F.3d 593, 600-01 (8th Cir. 2016)' appears not to exist and misreferences 823 F.3d 593 (which is an 11th Cir. decision, Foudy v. Miami-Dade County); the Court could not locate the cited Eighth Circuit case.
Misrepresented (Case Law)

Case cited as 'Earth to Go v. Midwest Coal, 682 S.W.3d 424 (Mo. App. 2024)' is incorrect; the correct citation is Earth to Go v. City of Richland, 706 S.W.3d 310 (Mo. Ct. App. 2025).
False Quotes (Case Law)

Quotations attributed to Harvey v. Timber Resources, 37 S.W.3d 814, 818 (Mo. Ct. App. 2001) were not found in Harvey and instead appear in BMK Corp. v. Clayton Corp., 226 S.W.3d 179, 195 (Mo. Ct. App. 2007).
Misrepresented (Case Law)

Multiple federal and district opinions (e.g., Consultus orders, Kudabeck, Wagner, Vanderberg, Wegener, Marmo) were cited as supporting Rule 37(c)(1) propositions when they involved Daubert challenges or different issues and do not support the asserted 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

Order to Show Cause

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/2506/EUPHORIC_LLC_v_WESTPORT_COMMUNITY_USA_22_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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