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Lowrey v. City of Rio Rancho et al. (2)

Court
D. New Mexico
Jurisdiction
USA
Decided
2026-05-21
AI tool
Implied
Outcome
Warning (again)
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Plaintiff claimed Johnson requires an evidentiary hearing when material jurisdictional facts are disputed; court explained Johnson addresses attorney ethical limits on representation, not entitlement to an evidentiary hearing on jurisdiction. || Misrepresented: Case Law | Plaintiff asserted Galindo requires fact-finding when attorney authority or removal consent is disputed; Court found Galindo concerned disqualification in a different context and does not support Plaintiff's removal/hearing theory. || Misrepresented: Case Law | Plaintiff asserted Price mandates conflict-of-interest waivers and that absent waivers the Court must hold an evidentiary hearing; Court explained Price involved different issues and did not establish such a rule for removal/disqualification proceedings. || Fabricated: Case Law | Court previously warned Plaintiff for citing nonexistent cases and/or case law that misleads; Plaintiff continued to rely on such authority.

Sanction teardown · D. New Mexico, USA · 2026-05-21

Lowrey v. City of Rio Rancho et al. (2)

What happened

In D. New Mexico, 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:

  • Misrepresented (Case Law)
    Plaintiff claimed Johnson requires an evidentiary hearing when material jurisdictional facts are disputed; court explained Johnson addresses attorney ethical limits on representation, not entitlement to an evidentiary hearing on jurisdiction.
  • Misrepresented (Case Law)
    Plaintiff asserted Galindo requires fact-finding when attorney authority or removal consent is disputed; Court found Galindo concerned disqualification in a different context and does not support Plaintiff's removal/hearing theory.
  • Misrepresented (Case Law)
    Plaintiff asserted Price mandates conflict-of-interest waivers and that absent waivers the Court must hold an evidentiary hearing; Court explained Price involved different issues and did not establish such a rule for removal/disqualification proceedings.
  • Fabricated (Case Law)
    Court previously warned Plaintiff for citing nonexistent cases and/or case law that misleads; Plaintiff continued to rely on such authority.

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 (again)

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.

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Source: https://www.damiencharlotin.com/documents/2188/Lowrey_v._City_of_Rio_Rancho_USA_21_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2188/Lowrey_v._City_of_Rio_Rancho_USA_21_May_2026.pdf

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