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McCormick v. Texakoma Financial

Court
E.D. Texas
Jurisdiction
USA
Decided
2026-06-11
AI tool
Unidentified
Outcome
Public Reprimand; Monetary Sanction; Firmwide citation review; CLE
Monetary penalty
6000 USD

What was hallucinated

Fabricated: Case Law | A cited case, 'Noviello v. Bayview Asset Management, LLC, No. 3:18-cv-02057, 2019 WL 13175252, at *4 (N.D. Tex. Sept. 30, 2019)', was fictitious and does not exist as presented. || False Quotes: Case Law | Two quoted passages attributed to Texas v. American Blastfax, Inc. (164 F. Supp. 2d 892 (W.D. Tex. 2001)) do not appear in that opinion and were fabricated. || Misrepresented: Case Law | Citation to Gene & Gene LLC v. BioPay LLC, 541 F.3d 318 (5th Cir. 2008) was used to support a proposition about the §227(c)(5) safe-harbor requiring actual compliance, but the cited pages do not support that proposition. || Misrepresented: Case Law | Citation to Charvat v. GVN Mich., Inc., 561 F.3d 623 (6th Cir. 2009) was used to support a burdens-of-proof proposition that the court found unsupported by the cited material. || Misrepresented: Case Law | Citation to Shields Ltd. P'ship v. Bradberry, 526 S.W.3d 471 (Tex. 2017) was used to assert a duty-to-speak estoppel principle that the Court found the cited pages do not establish.

Sanction teardown · E.D. Texas, USA · 2026-06-11

McCormick v. Texakoma Financial

What happened

In E.D. Texas, 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)
    A cited case, 'Noviello v. Bayview Asset Management, LLC, No. 3:18-cv-02057, 2019 WL 13175252, at *4 (N.D. Tex. Sept. 30, 2019)', was fictitious and does not exist as presented.
  • False Quotes (Case Law)
    Two quoted passages attributed to Texas v. American Blastfax, Inc. (164 F. Supp. 2d 892 (W.D. Tex. 2001)) do not appear in that opinion and were fabricated.
  • Misrepresented (Case Law)
    Citation to Gene & Gene LLC v. BioPay LLC, 541 F.3d 318 (5th Cir. 2008) was used to support a proposition about the §227(c)(5) safe-harbor requiring actual compliance, but the cited pages do not support that proposition.
  • Misrepresented (Case Law)
    Citation to Charvat v. GVN Mich., Inc., 561 F.3d 623 (6th Cir. 2009) was used to support a burdens-of-proof proposition that the court found unsupported by the cited material.
  • Misrepresented (Case Law)
    Citation to Shields Ltd. P'ship v. Bradberry, 526 S.W.3d 471 (Tex. 2017) was used to assert a duty-to-speak estoppel principle that the Court found the cited pages do not establish.

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

Public Reprimand; Monetary Sanction; Firmwide citation review; CLE (monetary penalty: 6000 USD.)

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/2457/MATT_MCCORMICK_v._TEXAKOMA_FINANCIAL_INC_USA_11_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2457/MATT_MCCORMICK_v._TEXAKOMA_FINANCIAL_INC_USA_11_June_2026.pdf

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