What was hallucinated

False Quotes: Case Law | Counsel attributed quoted language about "extraneous prejudicial information" and "outside influence" to Miller although those phrases do not appear in Miller (they derive from MRE 606(b)(2)). || Misrepresented: Case Law | Counsel cited People v. Budzyn for a standard of review it does not state, using the case to support propositions it does not contain. || Fabricated: Case Law | Counsel cited a nonexistent opinion in a motion for a protective order. || Fabricated: Case Law | Counsel cited a nonexistent criminal appellate opinion in the new-trial motion. || Fabricated: Case Law | Counsel cited a nonexistent criminal appellate opinion in the new-trial motion. || Fabricated: Case Law | Counsel cited a nonexistent appellate case in the appellate brief.

Sanction teardown · CA Michigan, USA · 2026-06-17

Joyce Barber v. Lawrence J. Morawa, MD

What happened

In CA Michigan, 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:

False Quotes (Case Law)

Counsel attributed quoted language about "extraneous prejudicial information" and "outside influence" to Miller although those phrases do not appear in Miller (they derive from MRE 606(b)(2)).
Misrepresented (Case Law)

Counsel cited People v. Budzyn for a standard of review it does not state, using the case to support propositions it does not contain.
Fabricated (Case Law)

Counsel cited a nonexistent opinion in a motion for a protective order.
Fabricated (Case Law)

Counsel cited a nonexistent criminal appellate opinion in the new-trial motion.
Fabricated (Case Law)

Counsel cited a nonexistent criminal appellate opinion in the new-trial motion.
Fabricated (Case Law)

Counsel cited a nonexistent appellate case in the appellate brief.

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 remanded to consider sanctions; Bar Referral

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/2411/Barber_v._Morawa_USA_17_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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