What was hallucinated

Misrepresented: Case Law | Trustee relied on In re Sweports (7th Cir.) as 'binding' to require return of funds to debtor; court explained Sweports was a Chapter 11 jurisdictional case and inapplicable to these Chapter 13 facts. || Misrepresented: Case Law | Trustee cited Marshall v. Johnson and applied it incorrectly to argue trustees could deduct fees here; court found Marshall inapplicable and mischaracterized its holding. || False Quotes: Case Law | Trustee included altered or misleading quotations from authority without indicating alterations; court flagged misleading/modified quotations as one of the brief's deficiencies. || Fabricated: Legal Norm | Trustee cited a Bankruptcy Rule that does not exist (non-existent rule identified in Figure 3 of the decision); court listed this as a fabricated legal norm in the brief.

Sanction teardown · N.D. Indiana (Bankruptcy), USA · 2026-06-10

In re Garcia-Martz

What happened

In N.D. Indiana (Bankruptcy), 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)

Trustee relied on In re Sweports (7th Cir.) as 'binding' to require return of funds to debtor; court explained Sweports was a Chapter 11 jurisdictional case and inapplicable to these Chapter 13 facts.
Misrepresented (Case Law)

Trustee cited Marshall v. Johnson and applied it incorrectly to argue trustees could deduct fees here; court found Marshall inapplicable and mischaracterized its holding.
False Quotes (Case Law)

Trustee included altered or misleading quotations from authority without indicating alterations; court flagged misleading/modified quotations as one of the brief's deficiencies.
Fabricated (Legal Norm)

Trustee cited a Bankruptcy Rule that does not exist (non-existent rule identified in Figure 3 of the decision); court listed this as a fabricated legal norm in the brief.

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

Order to Show Cause

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/2507/In_re_Garcia-Martz_USA_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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