What was hallucinated

Fabricated: Case Law | Counsel cited two cases that do not appear to exist; the Court described these as hallucinated/fabricated citations. || False Quotes: Case Law | Counsel quoted material that does not exist in the cases purportedly quoted; the Court identified these as hallucinated quotations. || Misrepresented: Case Law | Counsel mischaracterized holdings and cited authorities that did not support the propositions for which they were offered.

Details

The Court found that plaintiff counsel submitted filings containing multiple AI-driven errors: two cited cases that do not appear to exist (fabricated citations), quotations that do not exist in the purported source cases (hallucinated quotations), and mischaracterizations of cited holdings. Following an order to show cause (here), Counsel admitted these errors at a show-cause hearing, blamed misuse/failure to verify outputs of AI tools, and published an article as remediation. The Court criticized the article as minimizing the misconduct but concluded counsel acted in good faith and, given their record and remedial efforts, discharged the show-cause order without imposing sanctions.

Sanction teardown · W.D. North Carolina, USA · 2026-06-16

Jacob Doe v. The University of North Carolina System, et al.

What happened

In W.D. North Carolina, 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)

Counsel cited two cases that do not appear to exist; the Court described these as hallucinated/fabricated citations.
False Quotes (Case Law)

Counsel quoted material that does not exist in the cases purportedly quoted; the Court identified these as hallucinated quotations.
Misrepresented (Case Law)

Counsel mischaracterized holdings and cited authorities that did not support the propositions for which they were offered.

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

No sanction (but strong disappointment)

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.

Check a brief before you file it → · See our live false-verify rate

Source: https://reason.com/volokh/2026/06/16/lawyers-bar-journal-article-discussing-their-ai-hallucination-errors-doesnt-entirely-satisfy-judge-but/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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