What was hallucinated

False Quotes: Case Law | Cited 'Klapper v. Graziano, 41 Misc 3d 401, 410 (Sup Ct 2013)' and attributed the statement that releases 'are enforceable and are not to be lightly set aside,' but the quoted language does not appear in the opinion. || False Quotes: Case Law | Cited 'Clark v. Velsiplast Corp., 88 A.D.2d 859 (1st Dep't 1982)' and quoted from it, but the citation is incorrect (actual case is People v Ford, 88 A.D.2d 859) and the quoted language does not appear. || Misrepresented: Case Law | Cited 'Shah v. Levy, 56 A.D.3d 574 (2d Dep't 2008)' for a proposition unrelated to that action; citation misrepresents the authority's relevance. || Fabricated: Case Law | Submission contained numerous other phantom cases and lengthy fabricated quotes generated by AI, as noted by the court.

Sanction teardown · SC New York, USA · 2026-04-24

Keefe v. BMakin Film Ltd

What happened

In SC New York, 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)

Cited 'Klapper v. Graziano, 41 Misc 3d 401, 410 (Sup Ct 2013)' and attributed the statement that releases 'are enforceable and are not to be lightly set aside,' but the quoted language does not appear in the opinion.
False Quotes (Case Law)

Cited 'Clark v. Velsiplast Corp., 88 A.D.2d 859 (1st Dep't 1982)' and quoted from it, but the citation is incorrect (actual case is People v Ford, 88 A.D.2d 859) and the quoted language does not appear.
Misrepresented (Case Law)

Cited 'Shah v. Levy, 56 A.D.3d 574 (2d Dep't 2008)' for a proposition unrelated to that action; citation misrepresents the authority's relevance.
Fabricated (Case Law)

Submission contained numerous other phantom cases and lengthy fabricated quotes generated by AI, as noted by the court.

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

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/2326/2_-_Keefe_v_BMakin_Film_Ltd.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template