Sanction teardown · N.D. Indiana, USA · 2026-04-01
Joseph Maldonado v. Professional Animal Retirement Center
What happened
In N.D. Indiana, 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:
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Misrepresented (Case Law)Cited a case identifier and Westlaw pin that do not match any order at that date; the named case exists under a different citation and does not support the asserted standing proposition.
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Misrepresented (Case Law)Cited WildEarth Guardians for the proposition that denial of information necessary for scientific work constitutes injury, but the decision does not support the ESA-related information-injury argument advanced.
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Misrepresented (Case Law)Cited In Defense of Animals v. NIH to support that loss of scientific data is an injury-in-fact, but the opinion is a FOIA case that does not address standing or scientific-injury doctrine.
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Misrepresented (Case Law)Cited FEC v. Akins as supporting that denial of information necessary for scientific work is a recognized injury; Akins discusses standing in the election context and does not support the ESA/data proposition asserted.
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Misrepresented (Case Law)Represented Ringling Bros. as holding that conservation/scientific professionals have standing when mistreatment disrupts their work; the D.C. Cir. opinion actually found the plaintiff's asserted desire to work with elephants speculative and relied on aesthetic-injury authority.
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Misrepresented (Case Law)Provided citations that return unrelated matters or cannot be located at the cited identifiers (examples include PETA-related citations that point to different jurisdictions or unrelated cases).
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
Monetary Sanction; Bar Referral (monetary penalty: 1500 USD.)
Additional detail
Order to show cause is here.
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/1963/Maldonado_Tiger_King_USA_1_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).