What was hallucinated

Fabricated: Case Law | Plaintiff cited Kelley v. Conan, 555 F.3d 630, 634 (8th Cir. 2009); the court could not locate this case and found the citation appears to be nonexistent. || Fabricated: Exhibits & Submissions | Plaintiff referenced 'Exhibit X' and 'Exhibit Y' in support of asserted meetings but did not file or locate those exhibits in the record; the court found the referenced exhibits were absent. || False Quotes: Case Law | Plaintiff cited and quoted language attributed to Diaz v. Pan American World Airways, Inc. but provided an incorrect citation and the quoted language does not appear in the actual Diaz opinion; the court noted the citation error and that the case does not address pretext. || False Quotes: Case Law | Plaintiff cited Villiarimo with an incorrect citation and attributed language not found in the actual Villiarimo decision; the court flagged the miscitation and misquotation. || Fabricated: Case Law | Plaintiff cited Springer v. Boeing, 138 Wash. App. 248 (1997); the court was unable to locate the case and noted the citation does not appear in legal databases. || False Quotes: Case Law | Plaintiff cited Bahrampour v. Lampert and attributed language and an employment-law proposition not present in that decision; the court noted the quotation/language does not appear in the cited opinion.

Sanction teardown · W.D. Washington, USA · 2025-12-22

Levy v. Google LLC

What happened

In W.D. Washington, 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)

Plaintiff cited Kelley v. Conan, 555 F.3d 630, 634 (8th Cir. 2009); the court could not locate this case and found the citation appears to be nonexistent.
Fabricated (Exhibits & Submissions)

Plaintiff referenced 'Exhibit X' and 'Exhibit Y' in support of asserted meetings but did not file or locate those exhibits in the record; the court found the referenced exhibits were absent.
False Quotes (Case Law)

Plaintiff cited and quoted language attributed to Diaz v. Pan American World Airways, Inc. but provided an incorrect citation and the quoted language does not appear in the actual Diaz opinion; the court noted the citation error and that the case does not address pretext.
False Quotes (Case Law)

Plaintiff cited Villiarimo with an incorrect citation and attributed language not found in the actual Villiarimo decision; the court flagged the miscitation and misquotation.
Fabricated (Case Law)

Plaintiff cited Springer v. Boeing, 138 Wash. App. 248 (1997); the court was unable to locate the case and noted the citation does not appear in legal databases.
False Quotes (Case Law)

Plaintiff cited Bahrampour v. Lampert and attributed language and an employment-law proposition not present in that decision; the court noted the quotation/language does not appear in the cited opinion.

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/1259/Levy_v._Google_USA_22_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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