Sanction teardown · Arizona State Bar, USA · 2026-03-13
John A. Griffiths
What happened
In Arizona State Bar, USA, a filing relied on Eve.legal to help draft legal argument. The court identified the following problems with the citations in that filing:
-
Fabricated (Case Law)Eve.legal supplied a citation for a case that does not exist; defense counsel flagged it as an AI-generated fabricated case.
-
Misrepresented (Case Law)Eve.legal provided a citation and a quotation attributed to a real case; the cited case did not support the proposition nor contain the quoted language.
Which AI tool
Eve.legal. 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
Reprimand and order to pay State Bar costs and expenses of $1,200. (monetary penalty: 1200 USD.)
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: Damien Charlotin's public AI Hallucination Cases Database (CC0).