What was hallucinated

Misrepresented: Case Law | "The Opinion says: “ In Dang v. Amarin Corp. PLC , the court applied the core operations doctrine where executives made misleading statements about Vascepa, the company’s only product, while ignoring FDA Form 483s and audits identifying significant regulatory risks.” Op. at 22. However, the Dangcourt dismissed the plaintiffs’ securities fraud complaint and specifically rejected the plaintiffs’ argument under the “core operations” doctrine. 7" || False Quotes: Case Law | "Similarly, the Opinion quotes Dang as referring to “classic evidence of scienter,” id. at 20, but the case does not contain that quote." || Misrepresented: Case Law | "Second, the Opinion relies on In re Intelligroup Securities Litigation, 527F. Supp. 2d262 (D. N.J. 2007), to support the followin g proposition: “Courts hav e repeatedly held that SOX certifications can support a strong inference of scienter when executives certify internal controls while aware of or recklessly disregarding serious deficien cies, especially when the iss ues pertain to cor e operations.” Op . at 24. [...] However, as in Dang, the court in Intelligroup granted the defendants’ motion to dismiss in its entirety." || False Quotes: Case Law | "Moreover, Intelligroup does not contain the quotation about “false statements in their own right,” as re ferenced in the Opinion. Op. at 24. || Fabricated: Case Law | "Third, the Opinion contains the following statement in the scienter section: “Similarly, in Stichting Pensioen fonds Metaalen Techniek v. Verizon Commc’ ns Inc .,No. 23-05218, 20 21WL35409 68, at* 1517 (S.D.N.Y.Au g. 10,2021), [...] We have not been able to identify this case from the Southern District of New York, but we believe the Court was referring to a case with the same caption from the District of New Jersey." || False Quotes: Case Law | Fourth, the Opinion attributes two quotes to City of Warwick Retirement System v. Catalent, Inc., No. 23-1108, 2024 WL 3219616 (D.N.J. June 28, 2024), but they are not contained in that case. Op. at 17 (“The absence of insider trading is not dispositive.”); id. (“The importance of the product to the company’s financial success supports the inference of s cienter.”). || False Quotes: Case Law | Fifth, the Opinion also attributes a quote to Roofer’s Pension Fund v. Papa, No. 16-2805, 2018 WL 3601229 (D.N.J. July 27, 2018), but the quote is not found in that case. Op. at 27 || False Quotes: Exhibits & Submissions | Finally, in addition to the above case citations, the Opinion attributes two quotes to Defendants that they are not alleged to have made.

Details

In a letter, the defendant pointed out the errors in the Opinion - prompting the judge to withdraw it through a minute order, without offering a rationale.The judge later issued a new opinion, without mentioning or addressing what had happened.In a context of a congressional investigation, the Judge later explained what happened, and blamed the intern.

Sanction teardown · D. New Jersey, USA · 2025-07-23

In Re CorMedix

What happened

In D. New Jersey, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

"The Opinion says: “ In Dang v. Amarin Corp. PLC , the court applied the core operations doctrine where executives made misleading statements about Vascepa, the company’s only product, while ignoring FDA Form 483s and audits identifying significant regulatory risks.” Op. at 22. However, the Dangcourt dismissed the plaintiffs’ securities fraud complaint and specifically rejected the plaintiffs’ argument under the “core operations” doctrine. 7"
False Quotes (Case Law)

"Similarly, the Opinion quotes Dang as referring to “classic evidence of scienter,” id. at 20, but the case does not contain that quote."
Misrepresented (Case Law)

"Second, the Opinion relies on In re Intelligroup Securities Litigation, 527F. Supp. 2d262 (D. N.J. 2007), to support the followin g proposition: “Courts hav e repeatedly held that SOX certifications can support a strong inference of scienter when executives certify internal controls while aware of or recklessly disregarding serious deficien cies, especially when the iss ues pertain to cor e operations.” Op . at 24. [...] However, as in Dang, the court in Intelligroup granted the defendants’ motion to dismiss in its entirety."
False Quotes (Case Law)

"Moreover, Intelligroup does not contain the quotation about “false statements in their own right,” as re ferenced in the Opinion. Op. at 24.
Fabricated (Case Law)

"Third, the Opinion contains the following statement in the scienter section: “Similarly, in Stichting Pensioen fonds Metaalen Techniek v. Verizon Commc’ ns Inc .,No. 23-05218, 20 21WL35409 68, at* 1517 (S.D.N.Y.Au g. 10,2021), [...] We have not been able to identify this case from the Southern District of New York, but we believe the Court was referring to a case with the same caption from the District of New Jersey."
False Quotes (Case Law)

Fourth, the Opinion attributes two quotes to City of Warwick Retirement System v. Catalent, Inc., No. 23-1108, 2024 WL 3219616 (D.N.J. June 28, 2024), but they are not contained in that case. Op. at 17 (“The absence of insider trading is not dispositive.”); id. (“The importance of the product to the company’s financial success supports the inference of s cienter.”).
False Quotes (Case Law)

Fifth, the Opinion also attributes a quote to Roofer’s Pension Fund v. Papa, No. 16-2805, 2018 WL 3601229 (D.N.J. July 27, 2018), but the quote is not found in that case. Op. at 27
False Quotes (Exhibits & Submissions)

Finally, in addition to the above case citations, the Opinion attributes two quotes to Defendants that they are not alleged to have made.

Which AI tool

ChatGPT. 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

Opinion withdrawn by judge

Additional detail

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: Damien Charlotin's public AI Hallucination Cases Database (CC0).

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