What was hallucinated

Fabricated: Legal Norm | Appellant cited a non-existent wording of art. 9 of Law 10.188/2001 (altered statutory text). Court found the quoted text does not exist in the law. || Fabricated: Case Law | Appellant attributed the phrase “A posse tolerada não configura esbulho e não autoriza indenização” to REsp nº 1.679.915-PA; court found the REsp is monocratic, criminal, from Pará, and does not contain that phrase.

Sanction teardown · TJ Parana, Brazil · 2026-05-25

Manoel Tomaz Budal Filho v. Antonio Carlos Alves Lopes

What happened

In TJ Parana, Brazil, 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 (Legal Norm)

Appellant cited a non-existent wording of art. 9 of Law 10.188/2001 (altered statutory text). Court found the quoted text does not exist in the law.
Fabricated (Case Law)

Appellant attributed the phrase “A posse tolerada não configura esbulho e não autoriza indenização” to REsp nº 1.679.915-PA; court found the REsp is monocratic, criminal, from Pará, and does not contain that phrase.

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

Monetary Fine; Bar Referral

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/2887/0002069-76.2026.8.16.0194.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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