Sanction teardown · S.D. Texas, USA · 2026-07-08

GS Holistic, LLC v. AAR Management LLC, et al.

What happened

In S.D. Texas, 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 (Case Law)
  Defendants cited Ochoa v. P.A.M. Transport, Inc. with an incorrect Westlaw identifier and wrong district/date; court corrected to Ochoa v. P.A.M. Transp., No. SA-17-cv-787, 2018 WL 7297889 (W.D. Tex. Aug. 15, 2018).
• Misrepresented (Case Law)
  Defendants cited Royal v. Integreon, Inc. with an incorrect Westlaw identifier and incorrect district/date; court corrected to Royal v. Integreon, Inc., No. 1:19-cv-822, 2020 WL 13836729 (W.D. Tex. Apr. 15, 2020).
• Misrepresented (Case Law)
  Defendants cited La. State Conference of the NAACP with an incorrect Westlaw identifier and wrong year; court corrected to La. State Conf. of the NAACP v. Louisiana, 490 F. Supp. 3d 982 (M.D. La. 2020).
• Misrepresented (Case Law)
  Defendants cited People’s Workshop, Inc. v. FEMA with an incorrect Westlaw identifier and incorrect decision year; court corrected to People’s Workshop, Inc. v. FEMA, No. CV 17-107, 2019 WL 1140196 (M.D. La. Mar. 12, 2019).
• Misrepresented (Case Law)
  Defendants cited Jimenez v. CitiMortgage with an incorrect Westlaw identifier and wrong opinion date; court corrected to Jimenez v. Citimortgage, Inc., No. CV SA-17-ca-00134, 2017 WL 11236934 (W.D. Tex. Apr. 3, 2017).

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

Admonishment

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/2576/Gs_Holistics_v._AAR_Management_USA_8_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).