What was hallucinated

Misrepresented: Case Law | Plaintiff cited Jimerson v. Tetlin Native Corp. as holding that transactions affecting ANCSA lands are invalid absent shareholder consent; the Court found that Jimerson concerned ANCSA stock transfers, not land, and did not support the plaintiff's claim. || Misrepresented: Case Law | Plaintiff relied on Akiachak as establishing federal oversight authority over ANCSA land transactions; the Court noted that Akiachak did not establish such a rule and that the D.C. Circuit dismissed the appeal for lack of jurisdiction. || Misrepresented: Case Law | Plaintiff cited Chugach Natives, Inc. v. Doyon, Ltd. to argue the 1996 deed was improper; the Court explained that Chugach concerned whether sand and gravel are part of the surface or subsurface estate and did not support the plaintiff's corporate-voting theory. || Fabricated: Legal Norm | Plaintiff relied on a non-existent or 'phantom' ANCSA provision purportedly imposing a shareholder-vote requirement for land transfers; the Court found no such provision in ANCSA and called the argument frivolous. || Fabricated: Exhibits & Submissions | Multiple citations in the plaintiff's filings contained incorrect or incomplete identifying information, which the Court noted required it to 'chase down nonexistent authorities' and admonished the plaintiff to verify accuracy of future citations.

Sanction teardown · D. Alaska, USA · 2026-04-23

Gunter v. Contango ORE, Inc., et al.

What happened

In D. Alaska, 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)

Plaintiff cited Jimerson v. Tetlin Native Corp. as holding that transactions affecting ANCSA lands are invalid absent shareholder consent; the Court found that Jimerson concerned ANCSA stock transfers, not land, and did not support the plaintiff's claim.
Misrepresented (Case Law)

Plaintiff relied on Akiachak as establishing federal oversight authority over ANCSA land transactions; the Court noted that Akiachak did not establish such a rule and that the D.C. Circuit dismissed the appeal for lack of jurisdiction.
Misrepresented (Case Law)

Plaintiff cited Chugach Natives, Inc. v. Doyon, Ltd. to argue the 1996 deed was improper; the Court explained that Chugach concerned whether sand and gravel are part of the surface or subsurface estate and did not support the plaintiff's corporate-voting theory.
Fabricated (Legal Norm)

Plaintiff relied on a non-existent or 'phantom' ANCSA provision purportedly imposing a shareholder-vote requirement for land transfers; the Court found no such provision in ANCSA and called the argument frivolous.
Fabricated (Exhibits & Submissions)

Multiple citations in the plaintiff's filings contained incorrect or incomplete identifying information, which the Court noted required it to 'chase down nonexistent authorities' and admonished the plaintiff to verify accuracy of future citations.

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/2059/Gunter_v._Contango_USA_23_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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