Sanction teardown · TS Puerto Rico, USA · 2026-04-21
In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry
What happened
In TS Puerto Rico, 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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Fabricated (Case Law)Promovidas attributed an ad verbatim quote to 'Suárez v. CMI Caribe, 180 DPR 367, 376 (2010)' that the Court found did not exist or was incorrectly attributed.
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Fabricated (Case Law)Promovidas cited 'Otero-Burgos v. Inter Med. Supplies, Inc., 137 DPR 841, 848 (1995)' and attributed a direct quote which the record shows was nonexistent or misattributed.
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Fabricated (Case Law)Promovidas cited 'Pérez v. Horizon Lines, 2020 TSPR 61' with an asserted quotation about Ley 100 that the Court determined was incorrectly attributed or nonexistent.
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Fabricated (Case Law)Promovidas attributed to 'Rosado v. ELA, 2004 TSPR 13' a textual statement on Ley 115 that the Court found was not supported by the cited decision.
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Fabricated (Case Law)Promovidas cited 'Colón v. Romero Barceló, 112 DPR 573 (1982)' and ascribed a direct quotation regarding Artículo 1802 which the Court found did not appear as quoted in that decision.
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Fabricated (Case Law)Promovidas cited 'Ramos Lozada v. E.L.A., 174 DPR 650 (2008)' attributing a quote on qualified immunity that the Court determined was incorrectly attributed or nonexistent.
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
Admonishment (monetary penalty: 1000 USD.)
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/2047/In_re_Mar%C3%ADa_V._IRIZARRY_CENTENO_USA_21_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).