Sanction teardown · SC Alabama, USA · 2026-04-24
Laurie Ibach and Mark Stewart v. Bruce Stewart
What happened
In SC Alabama, 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:
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Fabricated (Case Law)Cited a non-existent Nebraska Court of Appeals decision presented as on‑point; Court found the citation actually pointed to unrelated Iowa criminal cases.
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Fabricated (Case Law)Cited a purported Alabama Civil Appellate opinion that does not exist.
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Fabricated (Case Law)Cited an apparently fictitious Alabama case used to support tolling/estoppel arguments.
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False Quotes (Case Law)Attributed a quotation to Ex parte Helms that does not appear in that opinion; Court found the quoted language absent from Helms.
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False Quotes (Case Law)Attributed language to Ex parte Seabol regarding fiduciary concealment tolling the statute that the Court found is not in the cited pages of Seabol.
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Fabricated (Case Law)Cited a non-existent Alabama appellate decision repeatedly to support estoppel/limitations arguments.
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False Quotes (Case Law)Quoted Janowiak v. Tiesi as supporting a proposition; Court found the quoted material not present and the reporter/pinpoint citations mismatched.
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Fabricated (Case Law)Cited an apparently fabricated Illinois appellate opinion purportedly imposing constructive trust for undue influence; Court found no case matching the citation/style.
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
Adverse Costs Order; Doubled Costs; Filing Prohibition; Bar Referral (monetary penalty: 17200 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/2035/Ibach__Stewart_v._Steward_USA_24_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).