What was hallucinated

Fabricated: Legal Norm | Supplemental Response cited La. R.S. § 9:5774, a statute that does not exist; counsel acknowledged the citation was incorrect and should have cited La. Civ. Code art. 3357 et seq. || Misrepresented: Case Law | Cited 'In re Garcia' without a complete citation; attorney admitted the intended Garcia case "does not support the precise proposition for which it was cited," and the court found this to be an unverified AI-generated reference that rendered the pleading misleading. || Fabricated: Case Law | Supplemental Response cited 'In re Buttermilk Towne LLC,' which the court determined 'does not resolve to any opinion' (AI-generated case citation that does not appear to exist).

Details

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Sanction teardown · W.D. Louisiana (Bankruptcy), USA · 2026-04-09

In re Troylond Malon Wise

What happened

In W.D. Louisiana (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:

Fabricated (Legal Norm)

Supplemental Response cited La. R.S. § 9:5774, a statute that does not exist; counsel acknowledged the citation was incorrect and should have cited La. Civ. Code art. 3357 et seq.
Misrepresented (Case Law)

Cited 'In re Garcia' without a complete citation; attorney admitted the intended Garcia case "does not support the precise proposition for which it was cited," and the court found this to be an unverified AI-generated reference that rendered the pleading misleading.
Fabricated (Case Law)

Supplemental Response cited 'In re Buttermilk Towne LLC,' which the court determined 'does not resolve to any opinion' (AI-generated case citation that does not appear to exist).

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; CLE on AI; barred until compliance; Brief struck (monetary penalty: 2750 USD.)

Additional detail

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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/1989/In_re_Troylond_USA_9_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).