What was hallucinated

Fabricated: Case Law | Appellant cited "Davis v. Davis, 590 N.E.2d 1372 (Ohio Ct. App. 1990)" for the proposition that challenges to foreign-judgment jurisdiction must be made in the rendering court; trial court and opposing counsel could not locate the case at that citation. || Fabricated: Case Law | Appellant cited "Kaplan v. Tuennerman, 87 Ohio App.3d 43, 621 N.E.2d 717 (8th Dist.1993)" but the citation did not correspond to an authority supporting his quoted proposition and could not be located as cited. || Fabricated: Case Law | Appellant cited "Black v. Black, 175 Ohio App.3d 113, 2008-Ohio-1525 (8th Dist.)" and provided quotations that the actual authority (if any) did not contain; court found the citation unreliable and not supporting appellant's claim. || Fabricated: Case Law | Appellant cited "Brunswick Hills Twp. v. Bank of New York, 2007-Ohio-1480 (12th Dist.)" but the case and quoted material did not match the proposition advanced; court treated the citation as a hallucinated authority. || Fabricated: Case Law | Appellant cited "Moran v. Moran, 2012-Ohio-1841, ¶ 13 (10th Dist. Ct. App.)" in support of his jurisdictional argument; the court was unable to locate the case at that citation and found it to be among the AI-generated mis-citations.

Sanction teardown · CA Ohio (6d), USA · 2026-05-26

Guo v. Meade Motorcars, L.L.C.

What happened

In CA Ohio (6d), USA, a filing relied on Deepseek to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Appellant cited "Davis v. Davis, 590 N.E.2d 1372 (Ohio Ct. App. 1990)" for the proposition that challenges to foreign-judgment jurisdiction must be made in the rendering court; trial court and opposing counsel could not locate the case at that citation.
Fabricated (Case Law)

Appellant cited "Kaplan v. Tuennerman, 87 Ohio App.3d 43, 621 N.E.2d 717 (8th Dist.1993)" but the citation did not correspond to an authority supporting his quoted proposition and could not be located as cited.
Fabricated (Case Law)

Appellant cited "Black v. Black, 175 Ohio App.3d 113, 2008-Ohio-1525 (8th Dist.)" and provided quotations that the actual authority (if any) did not contain; court found the citation unreliable and not supporting appellant's claim.
Fabricated (Case Law)

Appellant cited "Brunswick Hills Twp. v. Bank of New York, 2007-Ohio-1480 (12th Dist.)" but the case and quoted material did not match the proposition advanced; court treated the citation as a hallucinated authority.
Fabricated (Case Law)

Appellant cited "Moran v. Moran, 2012-Ohio-1841, ¶ 13 (10th Dist. Ct. App.)" in support of his jurisdictional argument; the court was unable to locate the case at that citation and found it to be among the AI-generated mis-citations.

Which AI tool

Deepseek. 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 Sanction (monetary penalty: 100 USD.)

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/2237/Guo_v._Meade_Motorcars_USA_26_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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