Sanction teardown · S.D. Texas, USA · 2025-07-23
Karina Elizondo vs. City of Laredo
What happened
In S.D. Texas, 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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Fabricated (Case Law)Plaintiff’s response included fictitious case citations; the Court found some citations were fabricated rather than real cases.
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Misrepresented (Case Law)Four cited cases had wildly inaccurate citation details (case numbers, dates, reporters, Westlaw cites, page numbers, and federal vs. state courts).
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Misrepresented (Case Law)The response misrepresented the legal holdings of the cases it cited.
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; mandatory CLE in ethics/legal technology (monetary penalty: 2500 USD.)
Additional detail
Counsel admitted his law clerk used AI tools and failed to verify the citations. The court imposed a $2,500 monetary sanction, required completion of CLE in ethics/legal technology, and ordered service of the sanction order to the plaintiff.
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/641/Elizondo_v._City_of_Laredo_USA_23_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).