What was hallucinated

Fabricated: Case Law | Counsel cited 'James v. City of New York, 144 AD3d 604, 605 (1st Dept 2016)'; the court found no case at that citation and the actual James decision (144 A.D.3d 466) does not support counsel's argument. || Fabricated: Case Law | Counsel cited 'Johnson v. Stadtlander, 162 A.D.3d 1580 (4th Dept 2018)'; the court found no case with that caption or citation. || Misrepresented: Case Law | Counsel cited 'Board of Mgrs. of 28 Cliff St. Condominium v. Maguire, 191 AD3d 553 (1st Dept 2021)'; the court found no such citation and the actual Board of Managers case (191 A.D.3d 25) does not support the argument cited. || Fabricated: Case Law | Counsel cited 'Xiong v. Knight, 80 A.D.3d 1055 (3d Dept 2011)'; the court found no such case under that caption/citation (citation appears to correspond to a different caption).

Sanction teardown · SC New York, USA · 2025-09-15

Facey v. Fisher, Liane et al.

What happened

In SC New York, 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)

Counsel cited 'James v. City of New York, 144 AD3d 604, 605 (1st Dept 2016)'; the court found no case at that citation and the actual James decision (144 A.D.3d 466) does not support counsel's argument.
Fabricated (Case Law)

Counsel cited 'Johnson v. Stadtlander, 162 A.D.3d 1580 (4th Dept 2018)'; the court found no case with that caption or citation.
Misrepresented (Case Law)

Counsel cited 'Board of Mgrs. of 28 Cliff St. Condominium v. Maguire, 191 AD3d 553 (1st Dept 2021)'; the court found no such citation and the actual Board of Managers case (191 A.D.3d 25) does not support the argument cited.
Fabricated (Case Law)

Counsel cited 'Xiong v. Knight, 80 A.D.3d 1055 (3d Dept 2011)'; the court found no such case under that caption/citation (citation appears to correspond to a different caption).

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

Costs Order; Disclosure Obligations

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/827/Original_Source_Image.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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