What was hallucinated

Fabricated: Case Law | Plaintiff's counsel included AI-generated bogus legal citations in the response brief; the Court admonished counsel and ordered attendance at an ethics seminar. || Misrepresented: Exhibits & Submissions | Plaintiff's brief asserted Loyer reported psychiatric illness, daily meth use, severe withdrawal with hallucinations, and was uncooperative/anxious/angry; the Court found the cited medical records show the opposite (denials and 'unremarkable'/'appropriate').

Sanction teardown · E.D. Michigan, USA · 2025-03-21

Loyer v. Wayne County Michigan

What happened

In E.D. Michigan, 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's counsel included AI-generated bogus legal citations in the response brief; the Court admonished counsel and ordered attendance at an ethics seminar.
Misrepresented (Exhibits & Submissions)

Plaintiff's brief asserted Loyer reported psychiatric illness, daily meth use, severe withdrawal with hallucinations, and was uncooperative/anxious/angry; the Court found the cited medical records show the opposite (denials and 'unremarkable'/'appropriate').

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

Plaintiff's counsel ordered to attend an ethics seminar

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/699/Loyer_v_Wayne_County_Michigan.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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