Sanction teardown · D. New Jersey, USA · 2026-06-16

K.W. v. Ringwood Board of Education

What happened

In D. New Jersey, 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)
  Two quoted passages attributed to Lauren W. v. DeFlaminis were not found in the cited opinion.
• False Quotes (Case Law)
  Second quoted passage from Lauren W. v. DeFlaminis also not located by the court in the cited pages.
• Misrepresented (Case Law)
  Plaintiff cited M.D. v. Colonial Sch. Dist. for a proposition about C.H.; court found the cited pages (388-90) do not discuss C.H. (discussion begins at p.393).
• Misrepresented (Case Law)
  Plaintiff appended a parenthetical to K.D. that misstates K.D.'s content and misattributes Chao/Skidmore; court noted K.D. has no footnotes and did not cite Chao to Skidmore.
• Fabricated (Case Law)
  Court could not locate J.T. v. Depew Union Free Sch. Dist. under the cited reporter number; the cited reporter (63 F.4th 94) yields no results and the case name could not be located.
• False Quotes (Case Law)
  Quoted language attributed to S.H. v. State-Operated Sch. Dist. of Newark was not found in the cited opinion.
• False Quotes (Case Law)
  Plaintiff quoted Ridley Sch. Dist. v. M.R. with added language 'and deference'; court found the actual opinion reads differently.
• False Quotes (Case Law)
  Court could not locate the quoted language attributed to M.R. v. Ridley Sch. Dist. in the cited pages.
• False Quotes (Case Law)
  Quoted language ascribed to M.H. v. New York City Dep't of Educ. could not be located in the cited decision.
• Misrepresented (Case Law)
  Plaintiff's LEXIS reporter citation for D.A. led to an unrelated case; the D.N.J. opinion the court found (2009 WL 972605) does not contain the quoted language.
• Misrepresented (Case Law)
  Reporter designation for J.L. v. Mercer Island led to an unrelated Ninth Circuit decision; the actual Ninth Circuit IDEA opinion located does not contain the quoted language nor support the proposition.
• Misrepresented (Case Law)
  Plaintiff cited Capistrano Unified with a reporter that resolves to an unrelated case; the actual Ninth Circuit decision located does not contain the quoted language or support the proposition.

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

Warning

Additional detail

Order to explain available 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/2448/KW_v._Ringwood_Board_USA_16_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).