Sanction teardown · SC Georgia, USA · 2026-05-05

Hannah Renee Payne v. The State

What happened

In SC Georgia, 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)
  Numerous additional authorities cited in State's briefing (ADA Leslie identified twelve more and withdrew reliance on nine in appellate brief) were generated by AI and do not stand for the propositions for which they were offered.
• Fabricated (Case Law)
  Citation appears not to exist; cited in the trial court's September 12, 2025 order and State's briefing.
• Misrepresented (Case Law)
  Citation exists but court found it does not support the proposition for which it was cited in State filings and the trial court's order.
• Fabricated (Case Law)
  At least nine case citations in the trial court's order were identified as either non-existent or not supporting the propositions cited; these were generated by AI and not independently verified.

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; 6-month suspension from appearing before the Supreme Court; 12 hours CLE; trial court order vacated and case remanded

Additional detail

Video of oral argument here (part on hallucinations comes at 32:45); further response here.

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/2090/Payne_v._State.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).