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Lowery Wilkinson Lowery, LLC, et al. v. State of Illinois, et al.

Court
E.D. Oklahoma
Jurisdiction
USA
Decided
2025-07-31
AI tool
Implied
Outcome
Sanctions
Monetary penalty
None reported

What was hallucinated

Fabricated: Exhibits & Submissions | Plaintiffs attached a fabricated news-image captioned 'FBI raids Courthouse' as an exhibit; the court treated it as a forged, improper submission and cited it in support of sanctions. || Fabricated: Exhibits & Submissions | Plaintiffs offered an email purportedly from ARDC official Rachel Miller to show bias; Miller submitted an affidavit alleging the email is a forgery and the court treated it as likely falsified evidence. || Misrepresented: Case Law | Plaintiffs falsely asserted that Judge White authored McGirt and advanced related incorrect claims that McGirt was being 'implicitly reversed' by court rulings; the court found these representations of case law to be false and unresearched.

Details

The court found multiple filings and exhibits from the plaintiffs to be fabricated or misleading (including a forged email and a fabricated news-image) and that plaintiffs repeatedly misrepresented legal authority (e.g., falsely attributing authorship of McGirt). The court relied on these findings in its Rule 11/§1927/inherent-power sanctions analysis, granted sanctions, dismissed the amended complaint with prejudice, and set a hearing to determine reasonable attorneys' fees.

Sanction teardown · E.D. Oklahoma, USA · 2025-07-31

Lowery Wilkinson Lowery, LLC, et al. v. State of Illinois, et al.

What happened

In E.D. Oklahoma, 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 (Exhibits & Submissions)
    Plaintiffs attached a fabricated news-image captioned 'FBI raids Courthouse' as an exhibit; the court treated it as a forged, improper submission and cited it in support of sanctions.
  • Fabricated (Exhibits & Submissions)
    Plaintiffs offered an email purportedly from ARDC official Rachel Miller to show bias; Miller submitted an affidavit alleging the email is a forgery and the court treated it as likely falsified evidence.
  • Misrepresented (Case Law)
    Plaintiffs falsely asserted that Judge White authored McGirt and advanced related incorrect claims that McGirt was being 'implicitly reversed' by court rulings; the court found these representations of case law to be false and unresearched.

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

Sanctions

Additional detail

The court found multiple filings and exhibits from the plaintiffs to be fabricated or misleading (including a forged email and a fabricated news-image) and that plaintiffs repeatedly misrepresented legal authority (e.g., falsely attributing authorship of McGirt). The court relied on these findings in its Rule 11/§1927/inherent-power sanctions analysis, granted sanctions, dismissed the amended complaint with prejudice, and set a hearing to determine reasonable attorneys' fees.

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/2122/Lowery_v._Illinois_USA_30_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2122/Lowery_v._Illinois_USA_30_July_2025.pdf

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