Sanction teardown · D. Kansas, USA · 2026-03-31
Ford v. Sherwin-Williams
What happened
In D. Kansas, 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 attributed a quotation to 'Clark v. City of Shawnee, Kansas, No. 21-2223-EFM, 2021 WL 4129476 (D. Kan. Sept. 9, 2021)', but the Westlaw number and case number pointed to unrelated authority; court concluded the citation/quotation was fictitious and likely AI-generated.
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
Additional detail
The district court identified fabricated citations and quotations in the pro se plaintiff's filings (e.g., a cited Westlaw number and case caption that did not match the cited authority). The court suspected the citations were AI-generated, cautioned the plaintiff, and referenced D. Kan. Standing Order 26-01 warning of possible sanctions for fabricated or incorrect legal authority. No sanction was imposed in this Order.
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/1907/Ford_v_Sherwin-Williams_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).