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In re: Valsartan

Court
D. New Jersey
Jurisdiction
USA
Decided
2025-09-03
AI tool
Implied
Outcome
Motion to exclude Expert opinions denied
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Dr. Sawyer cited non-existent sources generated by an AI tool; court found the sources were fabricated due to lack of verification.

Details

The Special Master found that Dr. Sawyer cited non-existent sources produced by an AI tool without adequate verification. The court concluded the opinions themselves were otherwise reliable and denied exclusion, while allowing cross-examination and noting that an award of costs might be appropriate.

Sanction teardown · D. New Jersey, USA · 2025-09-03

In re: Valsartan

What happened

In D. New Jersey, 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)
    Dr. Sawyer cited non-existent sources generated by an AI tool; court found the sources were fabricated due to lack of verification.

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

Motion to exclude Expert opinions denied

Additional detail

The Special Master found that Dr. Sawyer cited non-existent sources produced by an AI tool without adequate verification. The court concluded the opinions themselves were otherwise reliable and denied exclusion, while allowing cross-examination and noting that an award of costs might be appropriate.

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://reason.com/volokh/2025/12/07/expert-report-admitted-despite-ai-hallucinations-in-citations/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://reason.com/volokh/2025/12/07/expert-report-admitted-despite-ai-hallucinations-in-citations/

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