What was hallucinated

Fabricated: Case Law | Cited 'Burton v. Ghosh, 961 F.3d 1084, 1092 (7th Cir. 2020)'; the court determined the citation does not correspond to that case and is a fabrication. || Fabricated: Case Law | Cited 'Iseminger v. Dist. Ct., 915 F.2d 1314 (10th Cir. 1990)' and 'Affolder v. Johnson, 53 F.3d 1178 (10th Cir. 1995)'; court found these reporter citations lead to different, unrelated opinions and treated them as fabrications. || Fabricated: Case Law | Cited 'Bentley v. United States, 41 F.3d 593, 604 (10th Cir. 1994)' and 'Clean Boat v. United States, 833 F.3d 1224 (10th Cir. 2016)'; court found the pin cites lead to different actual cases and treated them as fabricated or mis-cited. || Fabricated: Case Law | Several fabricated citations in Biglow's motions (e.g., Paula Denogean, Young v. Nationstar, Singleton v. Wulff, In re Delta/Airtran, Saxena v. Allen, Jones v. State of Colorado) were identified by the court as non-existent or incorrect. || False Quotes: Case Law | Attributed a quote about opposing counsel preying on pro se ignorance to Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840; the court found no such language in Garrett. || Fabricated: Case Law | Cited 'Ricks v. Lindsay, 480 F.2d 538 (10th Cir. 1973)' for waiver; court found the citation actually leads to Hanley v. Four Corners Vacation Properties, Inc., 480 F.2d 536 and does not support Biglow's proposition.

Sanction teardown · 10th Cir. CA, USA · 2026-03-24

Kevin Lee Biglow v. Dell Technologies Inc.

What happened

In 10th Cir. CA, 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)

Cited 'Burton v. Ghosh, 961 F.3d 1084, 1092 (7th Cir. 2020)'; the court determined the citation does not correspond to that case and is a fabrication.
Fabricated (Case Law)

Cited 'Iseminger v. Dist. Ct., 915 F.2d 1314 (10th Cir. 1990)' and 'Affolder v. Johnson, 53 F.3d 1178 (10th Cir. 1995)'; court found these reporter citations lead to different, unrelated opinions and treated them as fabrications.
Fabricated (Case Law)

Cited 'Bentley v. United States, 41 F.3d 593, 604 (10th Cir. 1994)' and 'Clean Boat v. United States, 833 F.3d 1224 (10th Cir. 2016)'; court found the pin cites lead to different actual cases and treated them as fabricated or mis-cited.
Fabricated (Case Law)

Several fabricated citations in Biglow's motions (e.g., Paula Denogean, Young v. Nationstar, Singleton v. Wulff, In re Delta/Airtran, Saxena v. Allen, Jones v. State of Colorado) were identified by the court as non-existent or incorrect.
False Quotes (Case Law)

Attributed a quote about opposing counsel preying on pro se ignorance to Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836, 840; the court found no such language in Garrett.
Fabricated (Case Law)

Cited 'Ricks v. Lindsay, 480 F.2d 538 (10th Cir. 1973)' for waiver; court found the citation actually leads to Hanley v. Four Corners Vacation Properties, Inc., 480 F.2d 536 and does not support Biglow's proposition.

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.

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Source: https://www.damiencharlotin.com/documents/1831/Biglow_v._Dell_USA_24_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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