What was hallucinated

Fabricated: Case Law | Brief cited a non-existent case; court's research found no such opinion. || Fabricated: Case Law | Brief cited a non-existent case; court's research found no such opinion. || Misrepresented: Case Law | Case was cited for the best-interest standard of review, but the court noted C.N. does not state that standard and was cited only in the unfitness section. || Misrepresented: Case Law | Case was cited for best-interest factors, but the court explained D.D. addressed only parental unfitness.

Details

The court imposed a monetary sanction of $1,000 on the appellate counsel and ordered a report to be sent to the Illinois Attorney Registration and Disciplinary Commission (ARDC).

Sanction teardown · CA Illinois, USA · 2025-08-07

In re S.M., a Minor

What happened

In CA Illinois, 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:

Fabricated (Case Law)

Brief cited a non-existent case; court's research found no such opinion.
Fabricated (Case Law)

Brief cited a non-existent case; court's research found no such opinion.
Misrepresented (Case Law)

Case was cited for the best-interest standard of review, but the court noted C.N. does not state that standard and was cited only in the unfitness section.
Misrepresented (Case Law)

Case was cited for best-interest factors, but the court explained D.D. addressed only parental unfitness.

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; report to ARDC (monetary penalty: 1000 .)

Additional detail

The court imposed a monetary sanction of $1,000 on the appellate counsel and ordered a report to be sent to the Illinois Attorney Registration and Disciplinary Commission (ARDC).

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/708/In_re_S.M..pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).