What was hallucinated

Fabricated: Case Law | Brief cited a nonexistent New York case for the standard of appellate review of summary judgment. || Misrepresented: Case Law | Brief mischaracterized the holding of a real case by attributing a rule about construing remedial statute exceptions that the opinion does not contain. || Misrepresented: Case Law | Brief represented that Rodgers held a two-year records search can be sufficient to establish lack of prior written notice; Rodgers did not address that issue. || Fabricated: Case Law | Brief cited a nonexistent Court of Appeals opinion and attributed a fabricated quotation about construing Admin. Code § 7-210 liberally. || Fabricated: Case Law | Brief quoted a fictitious appellate decision as declaring owners are 'in the best position to monitor and control' adjacent walkways; no such opinion exists at the cited citation.

Sanction teardown · CA NY (2d), USA · 2026-06-23

Landberg v City of New York

What happened

In CA NY (2d), 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)

Brief cited a nonexistent New York case for the standard of appellate review of summary judgment.
Misrepresented (Case Law)

Brief mischaracterized the holding of a real case by attributing a rule about construing remedial statute exceptions that the opinion does not contain.
Misrepresented (Case Law)

Brief represented that Rodgers held a two-year records search can be sufficient to establish lack of prior written notice; Rodgers did not address that issue.
Fabricated (Case Law)

Brief cited a nonexistent Court of Appeals opinion and attributed a fabricated quotation about construing Admin. Code § 7-210 liberally.
Fabricated (Case Law)

Brief quoted a fictitious appellate decision as declaring owners are 'in the best position to monitor and control' adjacent walkways; no such opinion exists at the cited citation.

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

Monetary Sanction (monetary penalty: 10500 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/2463/Landberg_v_City_of_New_York_USA_23_June_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