Sanction teardown · D. Maryland, USA · 2026-01-23
Future Field Solutions, LLC v. Van Norstrand
What happened
In D. Maryland, 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:
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Misrepresented (Exhibits & Submissions)Reply mischaracterized the pleadings by stating 'Count III of the Counterclaim principally seeks...equitable relief,' while the court observed Count III principally sought compensatory damages.
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Fabricated (Case Law)Reply contained incorrect or unspecified case citations and atypical errors suggesting non-vetted, AI-like drafting; court noted incorrect citations and unusual grammatical errors as part of the concern.
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Misrepresented (Exhibits & Submissions)Reply brief asserted that Defendants argued 'where there is no merger paper, there is no successor liability,' which the court found Defendants made no such argument.
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Misrepresented (Exhibits & Submissions)Reply brief claimed Defendants contended successor-liability doctrines do not apply to LLCs; court found no such argument in the record.
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Misrepresented (Exhibits & Submissions)Reply falsely asserted that Defendants migrated Van Norstrand's personal Google content into Office 365 and produced it, but the court records show Van Norstrand himself testified he migrated the content.
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Fabricated (Exhibits & Submissions)Reply contained materially incorrect factual timeline claims (e.g., alleging insider spouse-loans, PeriArchon purchase, Lockheed contract diversion, and lockouts occurred before dates supported by the record); court listed these as false assertions.
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.
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.
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Source: https://www.damiencharlotin.com/documents/1461/Future_Field_Solutions_LLC_v_Van_Norstrand_USA_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).