What was hallucinated

Misrepresented: Case Law | Plaintiff cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization). || False Quotes: Case Law | Plaintiff cited a Delaware decision from the Dow Chemical litigation (42 Del. J. Corp. L 509, C.A. No. 12090-VCG (2018)) and attributed two specific quoted statements to it; the court could not find those quoted statements in that opinion. || False Quotes: Case Law | Plaintiff referenced "Spence v. Spence" and attributed the quote “[d]ismissal is appropriate only if it is reasonably certain that the plaintiff could not prove any set of facts that would entitle him to relief.” Court located Spence v. Spence, 2012 WL 1495324 (Del. Super. Apr. 20, 2012) but the quoted language is not in that opinion; quote cannot be verified. || Misrepresented: Case Law | Plaintiff cited E.E.C. v. E.J.C., 457 A.2d 688 (Del. 1983) to support standing because harm to a business flows to the owner; court noted E.E.C. concerns a divorce valuation of a husband's sole proprietorship and does not support Plaintiff's asserted proposition.

Sanction teardown · SC Delaware, USA · 2025-03-12

Mark Lillard v. Offit Kurman, P.A.

What happened

In SC Delaware, 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 cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization).
False Quotes (Case Law)

Plaintiff cited a Delaware decision from the Dow Chemical litigation (42 Del. J. Corp. L 509, C.A. No. 12090-VCG (2018)) and attributed two specific quoted statements to it; the court could not find those quoted statements in that opinion.
False Quotes (Case Law)

Plaintiff referenced "Spence v. Spence" and attributed the quote “[d]ismissal is appropriate only if it is reasonably certain that the plaintiff could not prove any set of facts that would entitle him to relief.” Court located Spence v. Spence, 2012 WL 1495324 (Del. Super. Apr. 20, 2012) but the quoted language is not in that opinion; quote cannot be verified.
Misrepresented (Case Law)

Plaintiff cited E.E.C. v. E.J.C., 457 A.2d 688 (Del. 1983) to support standing because harm to a business flows to the owner; court noted E.E.C. concerns a divorce valuation of a husband's sole proprietorship and does not support Plaintiff's asserted proposition.

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

AI-use certification required for future filings

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/1529/Mark_Lillard_v._Offit_Kurman_USA_12_March_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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