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Farag v. Persante et al

Court
M.D. Florida
Jurisdiction
USA
Decided
2026-01-26
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Holt v. Crown Builders, Inc., 627 So.2d 1221 (Fla. 2d DCA 1993)'; court found this authority does not exist. || Fabricated: Case Law | Plaintiff cited 'Bennett v. Bivins, 685 Case 8:25-cv-03056-SDM-AEP,' which the court found to be nonexistent or erroneous. || Misrepresented: Legal Norm | Plaintiff misquoted Section 733.903, Florida Statutes; the quoted language does not appear in the statute and the court corrected the actual statutory text. || Misrepresented: Exhibits & Submissions | Plaintiff claimed Exhibit 1 was an entry of clerk's default, but the court found Exhibit 1 was not an entry of default. || Misrepresented: Exhibits & Submissions | Plaintiff asserted Exhibit 3 was a 'formal Certificate of Default'; court found Exhibit 3 was the plaintiff's motion for default, not an entered order. || Misrepresented: Exhibits & Submissions | Plaintiff alleged the lawyer appeared 'without any lawful authority or court approval,' but Exhibit 5 was the lawyer's notice of appearance filed in compliance with rules.

Sanction teardown · M.D. Florida, USA · 2026-01-26

Farag v. Persante et al

What happened

In M.D. Florida, 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)
    Plaintiff cited 'Holt v. Crown Builders, Inc., 627 So.2d 1221 (Fla. 2d DCA 1993)'; court found this authority does not exist.
  • Fabricated (Case Law)
    Plaintiff cited 'Bennett v. Bivins, 685 Case 8:25-cv-03056-SDM-AEP,' which the court found to be nonexistent or erroneous.
  • Misrepresented (Legal Norm)
    Plaintiff misquoted Section 733.903, Florida Statutes; the quoted language does not appear in the statute and the court corrected the actual statutory text.
  • Misrepresented (Exhibits & Submissions)
    Plaintiff claimed Exhibit 1 was an entry of clerk's default, but the court found Exhibit 1 was not an entry of default.
  • Misrepresented (Exhibits & Submissions)
    Plaintiff asserted Exhibit 3 was a 'formal Certificate of Default'; court found Exhibit 3 was the plaintiff's motion for default, not an entered order.
  • Misrepresented (Exhibits & Submissions)
    Plaintiff alleged the lawyer appeared 'without any lawful authority or court approval,' but Exhibit 5 was the lawyer's notice of appearance filed in compliance with rules.

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

Warning

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/1412/IBRAHIM_SHEHATTA_GERGES_FARAG_Plaintiff_v_ROBERT_PERSANTE_et_al_Defendants.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1412/IBRAHIM_SHEHATTA_GERGES_FARAG_Plaintiff_v_ROBERT_PERSANTE_et_al_Defendants.pdf

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