Sanction teardown · E.D. Michigan, USA · 2025-11-20
Evans, et al. v. Robertson et al. (3)
What happened
In E.D. Michigan, 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:
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False Quotes (Case Law)Provided a quotation attributed to Walden v. Fiore that does not appear in the opinion; court identified it as a false quote.
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Fabricated (Case Law)Cited a Michigan Court of Appeals case the court could not locate; treated as a fabricated case citation.
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Fabricated (Case Law)Cited an Eighth Circuit opinion that does not exist; court determined the citation refers to a different district-court filing.
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Fabricated (Case Law)Repeated citation used four times that the court could not find; treated as fabricated.
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Fabricated (Case Law)Citation identified by the court as not accurately representing an existing Sixth Circuit opinion.
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Fabricated (Case Law)Cited an E.D. Mich. opinion that does not exist and quoted language not found in any located opinion.
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Fabricated (Case Law)Cited a district-court opinion with a reporter citation that corresponds to a different case; court found the cited case does not exist as stated.
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Fabricated (Case Law)Cited multiple opinions and entries that the court could not locate and deemed factitious (repeatedly used in the brief).
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Fabricated (Case Law)Citation the court could not locate and treated as fabricated.
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Fabricated (Case Law)Cited a Ninth Circuit opinion that does not exist under the given citation; court identified it as fabricated.
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False Quotes (Case Law)Quoted Seay v. TVA about 'sur-replies are not permitted' but the court found the quotation does not appear in the opinion.
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False Quotes (Case Law)Attributed a quotation to Aetna Life Ins. Co. v. Ward that the court found does not exist in the opinion.
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False Quotes (Case Law)Attributed a quotation to United States v. Shaffer Equip. Co. that the court found to be fabricated.
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False Quotes (Case Law)Quoted Ready Transp. as stating that a stricken document 'ceases to exist for any purpose,' which the court found does not appear in that opinion.
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Misrepresented (Case Law)Cited a real Sixth Circuit case but relied on a proposition the opinion does not support; court characterized this as a misrepresentation of the 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
Multiple filings stricken from the record; Revocation of online upload privileges
Additional detail
Show Cause Order is here.
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://reason.com/volokh/2025/11/09/they-just-cant-help-it-ai-hallucination-edition/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).