What was hallucinated

Fabricated: Case Law | Motion cited a nonexistent case "In re Parkdale, LLC" to support that an LLC's assets are property of a member-debtor's estate; the court determined the case does not exist and was generated by AI. || Fabricated: Case Law | Motion cited a nonexistent case "In re Ahn" for the same proposition; the court determined the citation was fabricated by AI and did not exist.

Details

Counsel filed a motion containing case citations that did not exist; counsel admitted the citations were generated by Microsoft CoPilot and not independently verified. The court found a Rule 9011 violation, declined to impose monetary sanctions because of procedural limits and dismissal, and ordered CLE focused on AI ethics.

Sanction teardown · D. South Carolina (Bankruptcy), USA · 2025-08-27

In re Richburg

What happened

In D. South Carolina (Bankruptcy), USA, a filing relied on Microsoft CoPilot to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Motion cited a nonexistent case "In re Parkdale, LLC" to support that an LLC's assets are property of a member-debtor's estate; the court determined the case does not exist and was generated by AI.
Fabricated (Case Law)

Motion cited a nonexistent case "In re Ahn" for the same proposition; the court determined the citation was fabricated by AI and did not exist.

Which AI tool

Microsoft CoPilot. 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

3 hours of CLE to be proven

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/731/In_re_Richburg_USA_29_August_2025.PDF, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template