What was hallucinated

Misrepresented: Case Law | Plaintiff cited Sterling v. Velsicol Chem. Corp. as '855 P.2d 1188' and as a Colorado court decision; the Court noted the correct reporter and that Sterling is 855 F.2d 1188 (Sixth Circuit), not a Colorado decision. || False Quotes: Case Law | Plaintiff attributed a quotation warning against dismissals that would 'strip a court of its ability to afford complete relief' to Citizen Center v. Gessler; the Court found that language does not appear in Gessler. || Misrepresented: Case Law | Plaintiff cited Harris v. Sand Canyon Corp. using an apparently fabricated or incorrect Westlaw-style citation that does not match the case or proposition relied upon.

Sanction teardown · D. Colorado, USA · 2026-02-10

Labonte v. Bokf, et al.

What happened

In D. Colorado, 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:

Misrepresented (Case Law)

Plaintiff cited Sterling v. Velsicol Chem. Corp. as '855 P.2d 1188' and as a Colorado court decision; the Court noted the correct reporter and that Sterling is 855 F.2d 1188 (Sixth Circuit), not a Colorado decision.
False Quotes (Case Law)

Plaintiff attributed a quotation warning against dismissals that would 'strip a court of its ability to afford complete relief' to Citizen Center v. Gessler; the Court found that language does not appear in Gessler.
Misrepresented (Case Law)

Plaintiff cited Harris v. Sand Canyon Corp. using an apparently fabricated or incorrect Westlaw-style citation that does not match the case or proposition relied upon.

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/1492/JOSHUA_WARREN_LABONTE_Plaintiff_v_BOKF_NA_UNIVERSAL_LENDING_CORPORATION_MO.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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