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Jackson Federation of Teachers, et al. v. Lynn Fitch

Court: S.D. Mississippi
Jurisdiction: USA
Decided: 2025-07-20
AI tool: Perplexity
Outcome: Judge withdrew the order
Monetary penalty: None reported

What was hallucinated

Misrepresented: Exhibits & Submissions | The TRO Order states that “[t]he Amended Complaint names the following Plaintiffs”: “Mississippi Association of Educators (MAE)”; “Dr. Daphne Chamberlain – faculty member at Tougaloo College”; “Dr. Robert Luckett – faculty member at Jackson State University”; “Dr. Brian Pugh - executive director of the Stennis Institute of Government at Mississippi State University”; “Z. Luckett – parent of public school children in Mississippi”; “Mississippi Votes – a nonprofit organization focused on civic engagement”; “Black Student Union at Jackson State University”; “Spectrum – a student organization at Jackson State University representing LGBTQ+ students”; “Aidan Carr – student at Millsaps College”; “Christopher Brent – student at Jackson State University”; “Mississippi Library Association”; and “Delta Sigma Theta Sorority, Inc. – Mississippi Chapters.” ECF #51 at 1, n.1. As confirmed by this Court’s docket, of the parties identified in footnote 1 of the TRO Order as “Plaintiffs,” only one—viz., Mississippi Association of Educators1—is or has ever been a named plaintiff in this case. See ECF #1, #22 || Misrepresented: Exhibits & Submissions | The TRO Order states that the First Amended Complaint names as “specific institutional impacts” the “cessation of DEI offices and initiatives at Jackson State University, Alcorn State University, and Hinds Community College” and “cancellation of implicit bias and Safe Zone training.” ECF #51 at 4. None of these allegations appears in the Amended Complaint. See ECF #22 || Misrepresented: Exhibits & Submissions | The TRO Order further states that “[a]t least three public institutions— Jackson State University, Alcorn State University, and Hinds Community College— allegedly already have terminated DEI initiatives and cancelled scheduled programming.” ECF #51 at 7-8. No such allegations appear in the Amended Complaint, and Defendants have not identified any record evidence supporting this finding. || Misrepresented: Exhibits & Submissions | Similarly, the TRO Order states that “[a]t Jackson State University, faculty members have been instructed not to discuss gender theory or historical interpretations involving systemic racism,” and that “Hinds Community College has cancelled Safe Zone training previously mandatory for staff, and faculty members report confusion over whether discussing concepts such as intersectionality or implicit bias violates HB 1193. ECF #51 at 12. No such allegations appear in the Amended Complaint, and Defendants have not identified any record evidence supporting these findings. || False Quotes: Legal Norm | The TRO Order further states that H.B. 1193 prohibits the dissemination, endorsement, or engagement with “race or sex stereotyping,” “race or sex scapegoating,” and “critical race theory,” all three terms being referenced in the TRO Order with quotation marks, as if excerpted verbatim from H.B. 1193. Id. at 9. However, none of these quoted terms appears in the text of H.B. 1193. See ECF #11-14. Similarly, the TRO Order elsewhere states that H.B. 1193 contains undefined terms such as “critical race theory” and “institutional bias,” both being referenced in the TRO Order with quotation marks, as if excerpted verbatim from H.B. 1193. ECF #51 at 11. Yet neither of these terms appears in the text of H.B. 1193. SeeECF #11-14 || Misrepresented: Exhibits & Submissions | Finally, as support for the Court’s ruling, the TRO Order references the declarations of four individuals identified as Brandy Williams, Leslie-Burl McLemore, Dr. Rhea Bishop, and Natalie Collier. ECF #51 at 14-15. The TRO Order identifies ECF #111, #11-2, #11-3, and #11-4, respectively, as the source of these declarations. See ECF #51at 14-15, nn.13-16. But those record citations in fact reflect the declarations of others who are not referenced in the TRO Order (namely, Carmen Dunn, Barbara Phillips, D’Andra Orey, and Cliff Johnson, respectively), which declarations contain content that is substantively different from the content referenced in the TRO Order. In fact, the four aforementioned declarations referenced in the TRO Order do not appear in this record at all.

Details

Story here, including a link to the original order full of hallucinations.Judge did not explain why he withdrew the original order and replaced it with a new one, prompting counsel to move for a preservation of the record and an explanation (motion).The judge dismissed the motion on 1 August 2025, stating: "The original version of that Order contained clerical errors referencing improper parties and factual allegations. The Court promptly corrected those errors and issued an Amended and Corrected TRO on the docket. [...] The Court corrected the record, notified the parties, and the corrected TRO is the controlling order. No further explanation is warranted."In the context of a subsequent congressional investigation, the judge explained what happened, and blamed his law clerk.

Sanction teardown · S.D. Mississippi, USA · 2025-07-20

Jackson Federation of Teachers, et al. v. Lynn Fitch

What happened

In S.D. Mississippi, USA, a filing relied on Perplexity to help draft legal argument. The court identified the following problems with the citations in that filing:

Issue

Misrepresented: Exhibits & Submissions | The TRO Order states that “[t]he Amended Complaint names the following Plaintiffs”: “Mississippi Association of Educators (MAE)”; “Dr. Daphne Chamberlain – faculty member at Tougaloo College”; “Dr. Robert Luckett – faculty member at Jackson State University”; “Dr. Brian Pugh - executive director of the Stennis Institute of Government at Mississippi State University”; “Z. Luckett – parent of public school children in Mississippi”; “Mississippi Votes – a nonprofit organization focused on civic engagement”; “Black Student Union at Jackson State University”; “Spectrum – a student organization at Jackson State University representing LGBTQ+ students”; “Aidan Carr – student at Millsaps College”; “Christopher Brent – student at Jackson State University”; “Mississippi Library Association”; and “Delta Sigma Theta Sorority, Inc. – Mississippi Chapters.” ECF #51 at 1, n.1. As confirmed by this Court’s docket, of the parties identified in footnote 1 of the TRO Order as “Plaintiffs,” only one—viz., Mississippi Association of Educators1—is or has ever been a named plaintiff in this case. See ECF #1, #22
Issue

Misrepresented: Exhibits & Submissions | The TRO Order states that the First Amended Complaint names as “specific institutional impacts” the “cessation of DEI offices and initiatives at Jackson State University, Alcorn State University, and Hinds Community College” and “cancellation of implicit bias and Safe Zone training.” ECF #51 at 4. None of these allegations appears in the Amended Complaint. See ECF #22
Issue

Misrepresented: Exhibits & Submissions | The TRO Order further states that “[a]t least three public institutions— Jackson State University, Alcorn State University, and Hinds Community College— allegedly already have terminated DEI initiatives and cancelled scheduled programming.” ECF #51 at 7-8. No such allegations appear in the Amended Complaint, and Defendants have not identified any record evidence supporting this finding.
Issue

Misrepresented: Exhibits & Submissions | Similarly, the TRO Order states that “[a]t Jackson State University, faculty members have been instructed not to discuss gender theory or historical interpretations involving systemic racism,” and that “Hinds Community College has cancelled Safe Zone training previously mandatory for staff, and faculty members report confusion over whether discussing concepts such as intersectionality or implicit bias violates HB 1193. ECF #51 at 12. No such allegations appear in the Amended Complaint, and Defendants have not identified any record evidence supporting these findings.
False Quotes (Legal Norm)

The TRO Order further states that H.B. 1193 prohibits the dissemination, endorsement, or engagement with “race or sex stereotyping,” “race or sex scapegoating,” and “critical race theory,” all three terms being referenced in the TRO Order with quotation marks, as if excerpted verbatim from H.B. 1193. Id. at 9. However, none of these quoted terms appears in the text of H.B. 1193. See ECF #11-14. Similarly, the TRO Order elsewhere states that H.B. 1193 contains undefined terms such as “critical race theory” and “institutional bias,” both being referenced in the TRO Order with quotation marks, as if excerpted verbatim from H.B. 1193. ECF #51 at 11. Yet neither of these terms appears in the text of H.B. 1193. SeeECF #11-14
Misrepresented (Exhibits & Submissions)

Finally, as support for the Court’s ruling, the TRO Order references the declarations of four individuals identified as Brandy Williams, Leslie-Burl McLemore, Dr. Rhea Bishop, and Natalie Collier. ECF #51 at 14-15. The TRO Order identifies ECF #111, #11-2, #11-3, and #11-4, respectively, as the source of these declarations. See ECF #51at 14-15, nn.13-16. But those record citations in fact reflect the declarations of others who are not referenced in the TRO Order (namely, Carmen Dunn, Barbara Phillips, D’Andra Orey, and Cliff Johnson, respectively), which declarations contain content that is substantively different from the content referenced in the TRO Order. In fact, the four aforementioned declarations referenced in the TRO Order do not appear in this record at all.

Which AI tool

Perplexity. 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

Judge withdrew the order

Additional detail

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: Damien Charlotin's public AI Hallucination Cases Database (CC0).

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