What was hallucinated

False Quotes: Case Law | Plaintiff cited Duff v. Trenton Beverage Co., 73 A.2d 578 (1950) for the proposition that a contract 'never becomes binding' if a condition precedent is not completed; the court found the quoted language does not appear in Duff. || False Quotes: Case Law | Plaintiff cited Mazziotti v. Allstate Ins. Co., 240 N.J. Super. 173, 180 (App. Div. 1990) to support a New Jersey-law proposition; the court found this citation to be incorrect (actual reported Mazziotti is 695 A.2d 1010 (Conn. 1997)) and the quoted language does not appear in the Connecticut case. || False Quotes: Case Law | Plaintiff cited Jordan v. Fox, Rothschild, O’Brien & Frankel, 20 F.3d 1250 (3d Cir. 1994) for the proposition that a district court 'may not consider matters extraneous to the pleadings' on a motion to dismiss; the court found that quoted language does not appear in Jordan.

Sanction teardown · D. New Jersey, USA · 2026-03-05

Lawand Hill v. Sloppy Vinyl, LLC, et al.

What happened

In D. New Jersey, 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:

False Quotes (Case Law)

Plaintiff cited Duff v. Trenton Beverage Co., 73 A.2d 578 (1950) for the proposition that a contract 'never becomes binding' if a condition precedent is not completed; the court found the quoted language does not appear in Duff.
False Quotes (Case Law)

Plaintiff cited Mazziotti v. Allstate Ins. Co., 240 N.J. Super. 173, 180 (App. Div. 1990) to support a New Jersey-law proposition; the court found this citation to be incorrect (actual reported Mazziotti is 695 A.2d 1010 (Conn. 1997)) and the quoted language does not appear in the Connecticut case.
False Quotes (Case Law)

Plaintiff cited Jordan v. Fox, Rothschild, O’Brien & Frankel, 20 F.3d 1250 (3d Cir. 1994) for the proposition that a district court 'may not consider matters extraneous to the pleadings' on a motion to dismiss; the court found that quoted language does not appear in Jordan.

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

Motion to dismiss granted; 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/1616/Hill_v._Sloppy_Vinyl_USA_5_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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