What was hallucinated

Fabricated: Case Law | Plaintiff relied on this purported Sixth Circuit decision in his motion to compel; the court identified the citation as fake and noted it as part of the problematic filings. || Fabricated: Case Law | Plaintiff cited this decision in his production-motion brief; the court characterized it as a fake citation appearing in the plaintiff's filings and tied to suspected generative-AI use. || Fabricated: Case Law | Plaintiff cited this case in his brief; the court identified the citation as fake and noted it among AI-generated phantom cases in the filing. || Fabricated: Case Law | Plaintiff cited this opinion; the court flagged the citation as a fake/invalid citation in the filing and linked it to suspected AI usage.

Sanction teardown · E.D. Michigan, USA · 2026-01-28

Hardy v. Genesee County Community Action Resource Department, et al. (1)

What happened

In E.D. Michigan, 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:

Fabricated (Case Law)

Plaintiff relied on this purported Sixth Circuit decision in his motion to compel; the court identified the citation as fake and noted it as part of the problematic filings.
Fabricated (Case Law)

Plaintiff cited this decision in his production-motion brief; the court characterized it as a fake citation appearing in the plaintiff's filings and tied to suspected generative-AI use.
Fabricated (Case Law)

Plaintiff cited this case in his brief; the court identified the citation as fake and noted it among AI-generated phantom cases in the filing.
Fabricated (Case Law)

Plaintiff cited this opinion; the court flagged the citation as a fake/invalid citation in the filing and linked it to suspected AI usage.

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

Two reply briefs stricken; warning

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/1433/GREGORY_HARDY_Plaintiff_v_GENESSE_COUNTY_COMMUNITY_ACTION_RESOURCE_DEPARTM.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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