Sanction teardown · AAA Tribunal, Domestic Arbitration; USA · 2026-08-07
In the Matter of the Arbitration between LawCatch, Inc. and Counsel Stack, Inc.
What happened
In AAA Tribunal, Domestic Arbitration; 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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False Quotes (Case Law)Counsel attributed the quote that failure to comply with a contractual notice-and-cure provision “precludes a claim for material breach” to BioVeris, but the tribunal found that BioVeris did not contain that language and did not address conditions precedent or futility.
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Misrepresented (Case Law)Counsel cited Capano at page *25 for the proposition that notice-and-cure is a condition precedent and that Delaware courts do not imply futility exceptions. The tribunal found that page *25 does not exist and that the opinion's only futility discussion concerned demand futility, not notice and cure.
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False Quotes (Case Law)Counsel represented that Salamone stated courts will not “rewrite” contract terms. The tribunal found that the word “rewrite” does not appear in the opinion.
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False Quotes (Case Law)Counsel attributed to GMG Capital the quotations “the objective theory of contracts” and that a contract's construction should be what “would be understood by an objective, reasonable third party.” The tribunal found that neither quotation appears in the opinion.
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
Not specified in source record.
Additional detail
Respondent's counsel relied on four Delaware authorities, but the tribunal found that the cited cases contained inaccurate quotations and descriptions of their holdings. The tribunal specifically identified nonexistent or unsupported quotations from BioVeris, Capano, Salamone, and GMG Capital, including claims that BioVeris and Capano treated notice-and-cure provisions as conditions precedent and that Capano addressed futility. The tribunal characterized the submission as fiction or reliance on fictitious authorities, found that it undermined the required likelihood of success and caused delay and expense, denied leave to file the dispositive motion, and ordered future filings to include compendia with quoted or cited passages highlighted.
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.
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Source: https://www.damiencharlotin.com/documents/3052/2026-08-07_Opinion_Denying_Motion_for_Leave.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).