Sanction teardown · N.D. Mississippi, USA · 2026-05-07
Joshua Harris v. Pinnacle Bank (2)
What happened
In N.D. Mississippi, 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 (Legal Norm)Plaintiff cited Fed. R. Civ. P. 11(b)(2) for a proposition unsupported by the rule's text; Court identified the inaccurate representation.
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Misrepresented (Legal Norm)Plaintiff relied on Fed. R. Civ. P. 11(b)(4) to argue sanctions require knowing or reckless conduct; Court found the rule was misapplied/misstated.
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Fabricated (Case Law)Plaintiff cited a non-existent Fifth Circuit case; Court found the citation fictitious.
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False Quotes (Case Law)Plaintiff attributed language to an existing Fifth Circuit case that does not appear in the opinion; Court noted the quotation was not in the decision.
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Fabricated (Legal Norm)Plaintiff cited a non-existent local rule; Court determined the rule does not exist.
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Fabricated (Legal Norm)Plaintiff cited a non-existent local rule; Court determined the rule does not exist.
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Fabricated (Case Law)Plaintiff cited a purported U.S. Supreme Court decision and page range that the Court found to be non-existent or fabricated.
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Fabricated (Case Law)Plaintiff cited a fabricated Fifth Circuit opinion with an impossible reporter/volume; Court found it fictitious.
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Fabricated (Legal Norm)Plaintiff cited a non-existent local rule in a later filing; Court found the rule fabricated.
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Fabricated (Legal Norm)Plaintiff cited a non-existent local rule in a later filing; Court found the rule fabricated.
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Misrepresented (Legal Norm)Plaintiff invoked Fed. R. Civ. P. 16(b)(3)(B) for a proposition not supported by the rule's text; Court noted the mischaracterization.
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
Case dismissed with prejudice as sanction
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/2128/Harris_v._Pinnacle_Bank_USA_7_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).