What was hallucinated

Fabricated: Case Law | Fabricated cases were used to support multiple incorrect legal propositions and each of petitioner's three assignments of error relied on fabricated authority. || Fabricated: Case Law | Opening brief included at least 10 fabricated case citations identified by PUC; the court found fabricated legal authority permeated the brief. || Fabricated: Case Law | Specific fabricated citation cited in the brief: 'McKay Creek Valley Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827 (2021)'; petitioner later claimed she intended a different, real McKay Creek Valley case.

Sanction teardown · CA Oregon, USA · 2026-04-06

Kelly Bartholomew v. Public Utility Commission of Oregon

What happened

In CA Oregon, 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:

Fabricated (Case Law)

Fabricated cases were used to support multiple incorrect legal propositions and each of petitioner's three assignments of error relied on fabricated authority.
Fabricated (Case Law)

Opening brief included at least 10 fabricated case citations identified by PUC; the court found fabricated legal authority permeated the brief.
Fabricated (Case Law)

Specific fabricated citation cited in the brief: 'McKay Creek Valley Ass’n v. Washington County, 309 Or App 112, 124-25, 482 P3d 827 (2021)'; petitioner later claimed she intended a different, real McKay Creek Valley case.

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

Judicial review dismissed due to submission of fabricated case citations

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.

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Source: https://www.damiencharlotin.com/documents/1934/Kelly_Bartholomew_v_Public_Utility_Commission_of_Oregon_USA_6_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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