Sanction teardown · CA Wisconsin, USA · 2025-08-07
Graham-Jackson v. Martin and Rock Prairie Farms, LLC
What happened
In CA Wisconsin, 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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Fabricated (Case Law)Opening brief cited legal authorities that do not exist; respondents flagged and court found violations of RULE 809.19(1)(e) and (4)(b).
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Misrepresented (Case Law)Opening brief cited existing authorities wholly unrelated to the propositions asserted; respondents identified and court found violations of briefing rules.
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Fabricated (Case Law)Reply brief repeated false legal citations, including non-existent authorities, after being put on notice; court imposed sanctions.
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Misrepresented (Case Law)Reply brief cited authorities unrelated to the propositions asserted, perpetuating the briefing-rule violations noted by the court.
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Fabricated (Case Law)Relied on non-existent authorities to oppose application of § 805.04 and argue he could unilaterally dismiss Rock Prairie Farms via amended complaint; court rejected as unsupported (fn. 6).
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Misrepresented (Case Law)Invoked WIS. STAT. § 971.13 and State v. Garfoot to require a competency determination in this civil action; court held those criminal-competency authorities inapplicable.
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 sanctions of $500 and requirement for future affidavit on legal citations (monetary penalty: 500 USD.)
Additional detail
Melvin Graham-Jackson, a pro se litigant, filed an appeal with false legal citations in his briefs, citing non-existent legal authorities and unrelated cases. The Court of Appeals identified this as a violation of Wisconsin's appellate rules. Despite being notified of these issues in the respondents' brief, Graham-Jackson continued to use false citations in his reply brief. The court imposed two sanctions: a $500 monetary penalty payable to the defendants to offset their legal expenses, and a requirement for Graham-Jackson to submit an affidavit in any future appeals certifying the accuracy and relevance of his legal citations.
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/707/Graham_Jackson_v._Martin.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).