What was hallucinated

False Quotes: Exhibits & Submissions | A block-quoted colloquy attributed to Ashley (including 'what he said, not what he did' and 'It was the language') is quoted as from Doc.55-1 at 33:2-11 but the court found those phrases do not appear at that location or elsewhere in the deposition. || False Quotes: Exhibits & Submissions | Plaintiff quotes exchanges purportedly showing Ashley answered 'No, not that I recall,' 'There was no contact,' and 'not threatening'; court found those quoted answers do not appear in the cited portions of Ashley's deposition (Doc.55-1 at 107:13-15,108:2-6,109:1-4). || False Quotes: Exhibits & Submissions | Plaintiff attributes to Spencer a block quote denying any threatening behavior after watching bodycam ('No. I didn't.' / 'He didn't do that'); court found those phrases and the quoted exchange do not appear at Doc.55-2 80:4-6,81:1-3. || False Quotes: Exhibits & Submissions | Plaintiff quotes Ashley as saying he concluded disorderly conduct 'after reviewing the video footage' (Doc.55-1 at 151:4-9); court found the deposition does not contain 'footage' or the asserted colloquy at the cited location. || False Quotes: Exhibits & Submissions | Plaintiff attributes to Ashley a short exchange ('No.' / 'So why did you arrest him?' / 'He said, "Take me to jail." I said, "Okay."') citing Doc.55-1 at 116:12-17; court found the quoted exchange as presented does not exist and omits surrounding context that contradicts the representation. || False Quotes: Exhibits & Submissions | Plaintiff quotes a long passage allegedly from Doc.55-1 at 161:22-162:16; the court found the precise quoted passage does not exist at that citation. || Fabricated: Exhibits & Submissions | Plaintiff's brief quotes Ashley as admitting the arrest was based solely on 'language' and that there were 'no threatening gestures or movements'; court found the quoted phrase does not appear at Doc.55-1 33:7-11 or elsewhere in the deposition. || Fabricated: Exhibits & Submissions | Brief asserts Ashley testified he did not determine probable cause until months later after reviewing video; court found the cited portion (Doc.55-1 at 151:4-13) does not support that statement and the word 'footage' does not appear there. || Fabricated: Exhibits & Submissions | Plaintiff claims both Ashley and Spencer confirmed Kennon made no threatening gestures and 'never chested up' in a disorderly-conduct manner; court found Ashley's cited testimony actually describes chesting up and Spencer's testimony differs, so the quoted summary is inaccurate/nonexistent.

Details

Plaintiff's counsel repeatedly quoted passages purportedly from defendants' depositions that the court found do not appear in the cited transcript pages; the court treated the pattern as egregious and ordered counsel to show cause under Rule 11.

Sanction teardown · D. Kansas, USA · 2026-02-18

Kennon v. Ashley

What happened

In D. Kansas, 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 (Exhibits & Submissions)

A block-quoted colloquy attributed to Ashley (including 'what he said, not what he did' and 'It was the language') is quoted as from Doc.55-1 at 33:2-11 but the court found those phrases do not appear at that location or elsewhere in the deposition.
False Quotes (Exhibits & Submissions)

Plaintiff quotes exchanges purportedly showing Ashley answered 'No, not that I recall,' 'There was no contact,' and 'not threatening'; court found those quoted answers do not appear in the cited portions of Ashley's deposition (Doc.55-1 at 107:13-15,108:2-6,109:1-4).
False Quotes (Exhibits & Submissions)

Plaintiff attributes to Spencer a block quote denying any threatening behavior after watching bodycam ('No. I didn't.' / 'He didn't do that'); court found those phrases and the quoted exchange do not appear at Doc.55-2 80:4-6,81:1-3.
False Quotes (Exhibits & Submissions)

Plaintiff quotes Ashley as saying he concluded disorderly conduct 'after reviewing the video footage' (Doc.55-1 at 151:4-9); court found the deposition does not contain 'footage' or the asserted colloquy at the cited location.
False Quotes (Exhibits & Submissions)

Plaintiff attributes to Ashley a short exchange ('No.' / 'So why did you arrest him?' / 'He said, "Take me to jail." I said, "Okay."') citing Doc.55-1 at 116:12-17; court found the quoted exchange as presented does not exist and omits surrounding context that contradicts the representation.
False Quotes (Exhibits & Submissions)

Plaintiff quotes a long passage allegedly from Doc.55-1 at 161:22-162:16; the court found the precise quoted passage does not exist at that citation.
Fabricated (Exhibits & Submissions)

Plaintiff's brief quotes Ashley as admitting the arrest was based solely on 'language' and that there were 'no threatening gestures or movements'; court found the quoted phrase does not appear at Doc.55-1 33:7-11 or elsewhere in the deposition.
Fabricated (Exhibits & Submissions)

Brief asserts Ashley testified he did not determine probable cause until months later after reviewing video; court found the cited portion (Doc.55-1 at 151:4-13) does not support that statement and the word 'footage' does not appear there.
Fabricated (Exhibits & Submissions)

Plaintiff claims both Ashley and Spencer confirmed Kennon made no threatening gestures and 'never chested up' in a disorderly-conduct manner; court found Ashley's cited testimony actually describes chesting up and Spencer's testimony differs, so the quoted summary is inaccurate/nonexistent.

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

Order to Show Cause

Additional detail

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/1557/Kennon_v._Ashley_USA_18_February_2026.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