Sanction teardown · E.D. Michigan, USA · 2026-04-06
Hardy v. Genesee County Community Action Resource Department, et al. (2)
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:
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False Quotes (Case Law)Court found the quoted phrase 'reason to believe' attributed to Berndt v. Tennessee does not appear in that opinion and the case does not address dismissal of litigants with mental issues.
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False Quotes (Case Law)Court found the phrase 'amateur psychologist' attributed to United States v. Frazier does not appear in that opinion and the criminal case does not address the issues raised.
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False Quotes (Case Law)Court found the plaintiff's reference to '17 Quarters of Silence' as arising from Williams v. Reed is inaccurate; Williams contains no such phrase and did not address discovery disputes.
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
Brief Struck
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.
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Source: https://www.damiencharlotin.com/documents/1954/Hardy_v._Genesse_USA_3_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).