What was hallucinated

False Quotes: Case Law | Attorney quoted a passage attributed to In re Marriage of Harrison that the court found to be entirely fabricated. || False Quotes: Case Law | Attorney quoted language attributed to In re Marriage of Swim that the court found fabricated. || Misrepresented: Case Law | Attorney attributed a two-part 'dual purposes' statement to Lenz v. Lenz that the court found does not appear in Lenz. || Misrepresented: Case Law | Attorney cited Dickerson v. State for the proposition that he was requesting oral argument though the case does not support that proposition. || Misrepresented: Case Law | Attorney cited In re A.S. as holding conservatorship orders must be specific enough to be enforceable by contempt, but the court found A.S. unrelated to that proposition.

Sanction teardown · CA Texas, USA · 2026-07-30

In the Interest of S.M.T. and S.J.T., Children

What happened

In CA Texas, 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:

False Quotes (Case Law)

Attorney quoted a passage attributed to In re Marriage of Harrison that the court found to be entirely fabricated.
False Quotes (Case Law)

Attorney quoted language attributed to In re Marriage of Swim that the court found fabricated.
Misrepresented (Case Law)

Attorney attributed a two-part 'dual purposes' statement to Lenz v. Lenz that the court found does not appear in Lenz.
Misrepresented (Case Law)

Attorney cited Dickerson v. State for the proposition that he was requesting oral argument though the case does not support that proposition.
Misrepresented (Case Law)

Attorney cited In re A.S. as holding conservatorship orders must be specific enough to be enforceable by contempt, but the court found A.S. unrelated to that proposition.

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

3 hours CLE

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/2752/In_the_interest_of_S.M.T._and_S.J.T._USA_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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