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LG Frankfurt, 13. Zivilkammer, 2-13 S 56/24

Court
LG Frankfurt (13. Zivilkammer)
Jurisdiction
Germany
Decided
2025-09-25
AI tool
Implied
Outcome
Court found the cited BGH decisions to be complete fabrications, admonished counsel for relying on or presenting invented authorities; no professional sanction was imposed in this decision.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | One of three purported BGH decisions quoted verbatim in the counsel's brief was a complete fabrication; the referenced fundstelle, date and Aktenzeichen do not exist. || Fabricated: Case Law | Second purported BGH decision cited with quotation marks proved nonexistent on analysis; the provided citation details were invented. || Fabricated: Case Law | Third purported BGH decision likewise lacked any matching record; the ZB-Aktenzeichen given would be inappropriate for Streitwertentscheidungen and do not exist.

Details

The plaintiff's counsel submitted a brief (10.08.2025) containing three purported BGH decisions quoted verbatim with fundstellen, dates, and Aktenzeichen. The court determined these citations were complete fabrications (non-existent references and inappropriate ZB-Aktenzeichen) and noted the counsel later admitted the falsity; the court observed that common chatbots can 'halluzinate' such authorities but held that a lawyer must verify sources and not incorporate unverified chatbot output into filings. The court applied this reasoning in evaluating the merits and admonished the professional duty to verify citations, but did not impose disciplinary sanctions in this order.

Sanction teardown · LG Frankfurt (13. Zivilkammer), Germany · 2025-09-25

LG Frankfurt, 13. Zivilkammer, 2-13 S 56/24

What happened

In LG Frankfurt (13. Zivilkammer), Germany, 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)
    One of three purported BGH decisions quoted verbatim in the counsel's brief was a complete fabrication; the referenced fundstelle, date and Aktenzeichen do not exist.
  • Fabricated (Case Law)
    Second purported BGH decision cited with quotation marks proved nonexistent on analysis; the provided citation details were invented.
  • Fabricated (Case Law)
    Third purported BGH decision likewise lacked any matching record; the ZB-Aktenzeichen given would be inappropriate for Streitwertentscheidungen and do not exist.

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

Court found the cited BGH decisions to be complete fabrications, admonished counsel for relying on or presenting invented authorities; no professional sanction was imposed in this decision.

Additional detail

The plaintiff's counsel submitted a brief (10.08.2025) containing three purported BGH decisions quoted verbatim with fundstellen, dates, and Aktenzeichen. The court determined these citations were complete fabrications (non-existent references and inappropriate ZB-Aktenzeichen) and noted the counsel later admitted the falsity; the court observed that common chatbots can 'halluzinate' such authorities but held that a lawyer must verify sources and not incorporate unverified chatbot output into filings. The court applied this reasoning in evaluating the merits and admonished the professional duty to verify citations, but did not impose disciplinary sanctions in this order.

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/2930/LG_Frankfurt_2-13_S_56-24_LARE250001360.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2930/LG_Frankfurt_2-13_S_56-24_LARE250001360.pdf

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