Sanction teardown · W.D. Louisiana, USA · 2026-05-18
Herbert Brooks v. Lowes Home Centers LLC
What happened
In W.D. Louisiana, 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)Counsel cited Tompkins v. Cyr for a rule about prior settlements/verdicts being irrelevant; the court could not find that language or the referenced topic in Tompkins.
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False Quotes (Case Law)Counsel relied on Collins v. Wayne Corp. to support the same proposition about prior settlements; the court found Collins unrelated to that issue.
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False Quotes (Case Law)Brief quoted 'the policy behind Rule 408 is to encourage settlements' and attributed it to Bankcard America; the court found Bankcard America uses 'purpose' not the quoted wording.
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False Quotes (Case Law)Counsel attributed the phrase 'must have acted in "bad faith"' to King v. Illinois Central R.R.; the court found the phrase is not present in the cited opinion.
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False Quotes (Case Law)Counsel quoted language about surgery and spoliation attributed to Gilliam v. Uni Holdings; the court found the quoted sentences do not appear at the cited pincite and the correct pages differ.
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False Quotes (Case Law)Brief quoted 'did not have a duty to delay his surgery' and cited Menges v. Cliffs Drilling Co.; the court found that quoted phrase does not appear in Menges at the cited location.
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False Quotes (Case Law)Brief quoted a sentence about the 'tortfeasor tak[ing] his victim as he finds him' and cited Lasha v. Olin Corp.; the court found the opinion uses 'defendant' (not 'tortfeasor') and the pincite was incorrect.
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
Monetary Sanction; CLE (monetary penalty: 1000 USD.)
Additional detail
Order to show cause is 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://reason.com/volokh/2026/05/19/instead-claude-just-made-up-more-stuff/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).