What was hallucinated

Fabricated: Case Law | Listed by the court as a fabricated authority cited by plaintiff. || Fabricated: Case Law | Included among the complaint's fake citations identified by the court. || Fabricated: Case Law | Plaintiff cited this case as addressing elements of fiduciary duty; the court found the citation does not exist and Westlaw search leads to an unrelated case. || Fabricated: Case Law | Listed by the court as one of the non-existent authorities cited in the complaint. || Fabricated: Case Law | Identified by the court among the complaint's fake citations. || Fabricated: Case Law | Included in the court's list of non-existent cases cited by plaintiff. || Fabricated: Case Law | Flagged by the court as a fake authority relied on in the complaint. || Fabricated: Case Law | One of the non-existent federal court citations the court identified in the complaint.

Sanction teardown · N.D. Alabama, USA · 2025-09-19

Martin v. Redstone Federal Credit Union

What happened

In N.D. Alabama, 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)

Listed by the court as a fabricated authority cited by plaintiff.
Fabricated (Case Law)

Included among the complaint's fake citations identified by the court.
Fabricated (Case Law)

Plaintiff cited this case as addressing elements of fiduciary duty; the court found the citation does not exist and Westlaw search leads to an unrelated case.
Fabricated (Case Law)

Listed by the court as one of the non-existent authorities cited in the complaint.
Fabricated (Case Law)

Identified by the court among the complaint's fake citations.
Fabricated (Case Law)

Included in the court's list of non-existent cases cited by plaintiff.
Fabricated (Case Law)

Flagged by the court as a fake authority relied on in the complaint.
Fabricated (Case Law)

One of the non-existent federal court citations the court identified in the complaint.

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

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/809/Martin_v._Redstone_Federal_Credit_Union.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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