What was hallucinated

False Quotes: Case Law | Motion included an alleged quotation that does not appear in the cited opinion; opposing counsel flagged the nonexistent quote from a Pennsylvania case. || Fabricated: Case Law | Multiple AI-generated, non-existent case opinions were cited in the Motion; Court identified eight defective citations. || Misrepresented: Case Law | Several real cases were cited but did not support the propositions asserted or were from inapposite jurisdictions (mischaracterized holdings).

Details

"Judges and commentators continue to warn lawyers about the risks of artificial intelligence shortcuts. We today address a more fundamental concern: lack of diligence and supervision of less experienced lawyers who can fairly expect supervision. The lawyers disregarded basic fundamental understandings learned in law school about the need to ensure the case citations presented to judges support what lawyers say they do. Counsel fell far short of this fundamental obligation warranting monetary sanctions against the New York co-counsel and non-monetary sanctions against both the New York co-counsel and her local Philadelphia co-counsel.Attorneys are again forewarned. Judges and their talented lawyers in Chambers scrutinize memoranda. Submissions containing unverified authority divert limited resources from other litigants who rely on their advocates’ careful research, accurate citation, and disciplined advocacy. These sanctions serve as a reminder the attorney’s oath of admission demands no less."

Sanction teardown · E.D. Pennsylvania, USA · 2026-01-26

Lifetime Well LLC v. IBSpot.com Inc.

What happened

In E.D. Pennsylvania, USA, a filing relied on Lexis+ AI; LexisNexis Protégé to help draft legal argument. The court identified the following problems with the citations in that filing:

False Quotes (Case Law)

Motion included an alleged quotation that does not appear in the cited opinion; opposing counsel flagged the nonexistent quote from a Pennsylvania case.
Fabricated (Case Law)

Multiple AI-generated, non-existent case opinions were cited in the Motion; Court identified eight defective citations.
Misrepresented (Case Law)

Several real cases were cited but did not support the propositions asserted or were from inapposite jurisdictions (mischaracterized holdings).

Which AI tool

Lexis+ AI; LexisNexis Protégé. 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; Order to share opinion with Professional Association (monetary penalty: 4000 .)

Additional detail

"Judges and commentators continue to warn lawyers about the risks of artificial intelligence shortcuts. We today address a more fundamental concern: lack of diligence and supervision of less experienced lawyers who can fairly expect supervision. The lawyers disregarded basic fundamental understandings learned in law school about the need to ensure the case citations presented to judges support what lawyers say they do. Counsel fell far short of this fundamental obligation warranting monetary sanctions against the New York co-counsel and non-monetary sanctions against both the New York co-counsel and her local Philadelphia co-counsel.Attorneys are again forewarned. Judges and their talented lawyers in Chambers scrutinize memoranda. Submissions containing unverified authority divert limited resources from other litigants who rely on their advocates’ careful research, accurate citation, and disciplined advocacy. These sanctions serve as a reminder the attorney’s oath of admission demands no less."

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/1398/Lifetime_v._IBSpot_USA_26_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).