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Jaii LeShawn Quinones v. Unknown Love, et al.

Court
E.D. Missouri
Jurisdiction
USA
Decided
2026-03-31
AI tool
Implied
Outcome
Show Cause Order
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Plaintiff cited "Egelhoff v. Egelhoff, 628 F.2d 346" for the proposition that arbitrary passport restrictions are unconstitutional; the Court found the reporter cite fabricated and the asserted holding incorrect (real case is Egelhoff v. Egelhoff, 532 U.S. 141 (2001), which does not say that). || Fabricated: Case Law | Plaintiff cited "Missouri ex rel. Wilkerson v. Wilkerson, 817 S.W.2d 77 (Mo. Ct. App. 1991)" and the Court found that citation does not exist as cited and does not support Plaintiff's proposition. || Fabricated: Case Law | Plaintiff cited "Robinson v. Missouri Child Support Agency, 2021 WL 5437824 (Mo. Ct. App. 2021)" but the Court concluded the citation does not exist or does not support the asserted proposition. || Misrepresented: Case Law | Plaintiff attributed to Haig v. Agee the proposition that "government-imposed passport restrictions must be justified by compelling evidence;" the Court explained Plaintiff's characterization is the opposite of the case's actual holding.

Sanction teardown · E.D. Missouri, USA · 2026-03-31

Jaii LeShawn Quinones v. Unknown Love, et al.

What happened

In E.D. Missouri, 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:

  • Misrepresented (Case Law)
    Plaintiff cited "Egelhoff v. Egelhoff, 628 F.2d 346" for the proposition that arbitrary passport restrictions are unconstitutional; the Court found the reporter cite fabricated and the asserted holding incorrect (real case is Egelhoff v. Egelhoff, 532 U.S. 141 (2001), which does not say that).
  • Fabricated (Case Law)
    Plaintiff cited "Missouri ex rel. Wilkerson v. Wilkerson, 817 S.W.2d 77 (Mo. Ct. App. 1991)" and the Court found that citation does not exist as cited and does not support Plaintiff's proposition.
  • Fabricated (Case Law)
    Plaintiff cited "Robinson v. Missouri Child Support Agency, 2021 WL 5437824 (Mo. Ct. App. 2021)" but the Court concluded the citation does not exist or does not support the asserted proposition.
  • Misrepresented (Case Law)
    Plaintiff attributed to Haig v. Agee the proposition that "government-imposed passport restrictions must be justified by compelling evidence;" the Court explained Plaintiff's characterization is the opposite of the case's actual holding.

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

Show Cause Order

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/1913/Quinones_v._Love_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1913/Quinones_v._Love_USA_31_March_2026.pdf

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