What was hallucinated

Fabricated: Case Law | Petition cited a non-existent case as 'Ex parte Holloway, 992 So. 2d 521, 524 (Ala. 2008)'; the reporter citation corresponds to an unrelated Louisiana case and the Alabama case does not exist. || False Quotes: Case Law | Petition included a quoted passage attributed to Ex parte Siderius (144 So. 3d 319 (Ala. 2013)) that cannot be found in that opinion or any known authority. || Misrepresented: Case Law | Petition cited two other real cases but misrepresented the holdings and discussion in those opinions (specific misstatements not identified in the opinion).

Details

Judge Bowden's dissent identifies that the mother's mandamus petition relied on multiple AI-generated hallucinations and misrepresentations of precedent: a fabricated case citation, a quoted passage attributed to a real Alabama case that cannot be found, and other misstatements of holdings. Bowden argued the petition should have been dismissed for failing to comply with Rule 21 and warned against the waste and unreliability caused by AI hallucinations; the majority did not impose sanctions and resolved the jurisdictional issues on the merits, granting mandamus in part.

Sanction teardown · CA Alabama, USA · 2026-06-26

Ex parte A.I.F.-H. f/k/a A.I.F.

What happened

In CA Alabama, 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)

Petition cited a non-existent case as 'Ex parte Holloway, 992 So. 2d 521, 524 (Ala. 2008)'; the reporter citation corresponds to an unrelated Louisiana case and the Alabama case does not exist.
False Quotes (Case Law)

Petition included a quoted passage attributed to Ex parte Siderius (144 So. 3d 319 (Ala. 2013)) that cannot be found in that opinion or any known authority.
Misrepresented (Case Law)

Petition cited two other real cases but misrepresented the holdings and discussion in those opinions (specific misstatements not identified in the opinion).

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.

Additional detail

Judge Bowden's dissent identifies that the mother's mandamus petition relied on multiple AI-generated hallucinations and misrepresentations of precedent: a fabricated case citation, a quoted passage attributed to a real Alabama case that cannot be found, and other misstatements of holdings. Bowden argued the petition should have been dismissed for failing to comply with Rule 21 and warned against the waste and unreliability caused by AI hallucinations; the majority did not impose sanctions and resolved the jurisdictional issues on the merits, granting mandamus in part.

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/2501/Ex_parte_A.I.F.-H._fka_A.I.F_USA_26_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).