What was hallucinated

Misrepresented: Exhibits & Submissions | Reply contained inaccurate timeline/factual assertions about when alleged actions occurred (court identified timing errors). || Misrepresented: Exhibits & Submissions | Reply claimed Counterclaim Defendants argued a point they did not (false characterization of opposing brief). || Misrepresented: Exhibits & Submissions | Reply falsely stated that Counterclaim Defendants migrated Van Norstrand's personal Google content into Office 365 and produced it; court found that Van Norstrand himself migrated the content. || Fabricated: Case Law | Reply included incorrect or erroneous case citations and other legal citations and grammatical errors flagged by opposing party and the court. || Misrepresented: Exhibits & Submissions | Reply attributed an argument to Counterclaim Defendants that they never made (false characterization).

Sanction teardown · D. Maryland, USA · 2026-01-23

Future Field Solutions v. Nordstrand

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:

Misrepresented (Exhibits & Submissions)

Reply contained inaccurate timeline/factual assertions about when alleged actions occurred (court identified timing errors).
Misrepresented (Exhibits & Submissions)

Reply claimed Counterclaim Defendants argued a point they did not (false characterization of opposing brief).
Misrepresented (Exhibits & Submissions)

Reply falsely stated that Counterclaim Defendants migrated Van Norstrand's personal Google content into Office 365 and produced it; court found that Van Norstrand himself migrated the content.
Fabricated (Case Law)

Reply included incorrect or erroneous case citations and other legal citations and grammatical errors flagged by opposing party and the court.
Misrepresented (Exhibits & Submissions)

Reply attributed an argument to Counterclaim Defendants that they never made (false characterization).

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

No Sanctions at this time

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/1393/FUTURE_FIELD_SOLUTIONS_LLC_et_al_v_ERIK_VAN_NORSTRAND.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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