Sanction teardown · S.D. New York, USA · 2026-03-09
M7 Indústria e Comércio de Compensados e Laminados v. U.S. Structural Plywood Integrity Coalition, et al.
What happened
In S.D. New York, 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:
-
False Quotes (Case Law)Plaintiffs' memorandum attributed this quoted passage to NYNEX Corp. v. Discon, but the Court found the quotation does not appear in that opinion.
-
False Quotes (Case Law)Plaintiffs' memorandum attributed this quoted passage to Int’l Railways of Cent. Am. v. United Brands Co., but the Court found the quotation does not appear in that opinion.
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
Order to show cause
Additional detail
The Court found two quotations in the Plaintiffs' memorandum that do not appear in the cited federal opinions and ordered counsel to explain and certify review of all cited cases before deciding whether to impose further sanctions.
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/1664/M7_v._Plywood_USA_9_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).