What was hallucinated

Fabricated: Case Law | Complaint included citations to opinions that do not exist; court identified these fabricated citations (noted in June 9, 2025 letter) and attributed them to likely AI misuse. || Misrepresented: Case Law | Complaint cited In re Marvel Ent. Grp. as supporting a heightened-duty proposition; court found the case does not support that proposition and flagged the citation as likely AI-generated. || Misrepresented: Case Law | Complaint cited other real opinions that did not plausibly stand for the propositions asserted by plaintiff; court treated these as misrepresentations likely from generative AI.

Sanction teardown · D. Delaware (Bankruptcy), USA · 2025-12-12

Jordan v. Beskrone (In re Prehired LLC)

What happened

In D. Delaware (Bankruptcy), 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)

Complaint included citations to opinions that do not exist; court identified these fabricated citations (noted in June 9, 2025 letter) and attributed them to likely AI misuse.
Misrepresented (Case Law)

Complaint cited In re Marvel Ent. Grp. as supporting a heightened-duty proposition; court found the case does not support that proposition and flagged the citation as likely AI-generated.
Misrepresented (Case Law)

Complaint cited other real opinions that did not plausibly stand for the propositions asserted by plaintiff; court treated these as misrepresentations likely from generative AI.

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

Second Amended Complaint dismissed

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/1244/in_re_Jordan_USA_12_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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