Sanction teardown · Massachusetts Land Court, USA · 2026-08-07
In the matter of Machinsky
What happened
In Massachusetts Land Court, 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:
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Fabricated (Legal Norm)Defendant attributed a non-existent quotation to G.L. c. 185, § 86; the court found the quoted language does not appear in that statute or elsewhere.
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Misrepresented (Case Law)Defendant cited Commonwealth v. LeBlanc as supporting recusal, but the court found LeBlanc irrelevant to recusal and not on point.
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Misrepresented (Case Law)Defendant cited Peterson v. Hopson and King v. Driscoll as authorities for limits on Rule 70, but the court noted neither case addresses Rule 70 or the duties of a commissioner and one predates the Rules.
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
Warning
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/2838/Machinsky_USA_7_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).