Sanction teardown · AC Illinois, USA · 2026-03-11
Kateryna Maslovska v. Ekaterina Shigabetdinova
What happened
In AC Illinois, 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)Four citations in the defendant's briefs were styled as legal authorities but did not exist or could not be verified; court noted they appeared to be AI-generated and unsupported.
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Misrepresented (Case Law)Two citations in the plaintiff's brief were cited for propositions they did not support; court characterized these as inaccurate/misrepresented citations likely produced by generative AI.
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 (both parties)
Additional detail
Appellate court found briefs from the parties contained six AI-style citations (four from defendant, two from plaintiff) that either did not exist or did not support the propositions for which they were cited. The court cautioned compliance with the Illinois Supreme Court Policy on AI but imposed no sanctions and affirmed the judgment due to an inadequate record on appeal.
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/1655/MASLOVSKA_v_EKATERINA_SHIGABETDINOVA_USA_11_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).