What was hallucinated

Fabricated: Case Law | Submitted 23 fictitious decisions across 19 submissions; court concluded these were fabricated AI-generated authorities and constituted frivolous conduct. || Misrepresented: Case Law | Materially misstated holdings of at least 83 genuine decisions across multiple filings; court found these misrepresentations extensive and non-trivial. || False Quotes: Case Law | Included multiple fictitious quotations and fabricated excerpts in filings; court treated fake quotations as aggravating evidence of AI hallucination misuse. || Fabricated: Case Law | Created and submitted additional fabricated authorities after opposing counsel identified the problem, exacerbating the misconduct.

Sanction teardown · SC New York, USA · 2026-08-04

Kleyman Law Group, P.C. v. Kaloidis

What happened

In SC New York, USA, a filing relied on Claude and other generative AI platforms to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Submitted 23 fictitious decisions across 19 submissions; court concluded these were fabricated AI-generated authorities and constituted frivolous conduct.
Misrepresented (Case Law)

Materially misstated holdings of at least 83 genuine decisions across multiple filings; court found these misrepresentations extensive and non-trivial.
False Quotes (Case Law)

Included multiple fictitious quotations and fabricated excerpts in filings; court treated fake quotations as aggravating evidence of AI hallucination misuse.
Fabricated (Case Law)

Created and submitted additional fabricated authorities after opposing counsel identified the problem, exacerbating the misconduct.

Which AI tool

Claude and other generative AI platforms. 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

Monetary Sanction; Bar Referral (monetary penalty: 46511 USD.)

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/2891/Kleyman_Law_Group_PC_v_Kaloidis_USA_4_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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