What was hallucinated

False Quotes: Case Law | Petitioner attributed the same quoted language to Nadarajah v. Gonzales, but the court found the quotation/mischaracterization inaccurate; Nadarajah concerned detention far exceeding six months. || False Quotes: Case Law | Petitioner quoted language—"detention is not permitted... even if the detention period has not yet exceeded six months."—attributed to Thai v. Ashcroft, but the quoted text does not appear in Thai and Thai involved detention exceeding 16 months.

Details

Order to Show Cause is here.

Sanction teardown · W.D. Washington, USA · 2026-06-02

Fadi El Bitar v. Julio Hernandez

What happened

In W.D. Washington, 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)

Petitioner attributed the same quoted language to Nadarajah v. Gonzales, but the court found the quotation/mischaracterization inaccurate; Nadarajah concerned detention far exceeding six months.
False Quotes (Case Law)

Petitioner quoted language—"detention is not permitted... even if the detention period has not yet exceeded six months."—attributed to Thai v. Ashcroft, but the quoted text does not appear in Thai and Thai involved detention exceeding 16 months.

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 Sanction (monetary penalty: 1000 USD.)

Additional detail

Order to Show Cause 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://www.damiencharlotin.com/documents/2255/El_bitar_v._Wamsley_USA_2_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).