What was hallucinated

Fabricated: Case Law | Court was unable to locate one of the plaintiff's cited cases and flagged it as likely fabricated; court noted inability to verify the citation and suspected AI generation. || False Quotes: Case Law | Court could not verify several quotations attributed to other cases in plaintiff's filings and flagged them as false or unverified quotations, suspecting AI origin.

Details

The court was unable to locate one of the plaintiff's case citations and several quotations attributed to other cases; the court suspected portions of the filings were AI-generated and noted potential Rule 11 violations but did not impose sanctions.

Sanction teardown · E.D. Missouri, USA · 2025-10-20

Megan Cowden v. US Treasury & IRS

What happened

In E.D. Missouri, 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)

Court was unable to locate one of the plaintiff's cited cases and flagged it as likely fabricated; court noted inability to verify the citation and suspected AI generation.
False Quotes (Case Law)

Court could not verify several quotations attributed to other cases in plaintiff's filings and flagged them as false or unverified quotations, suspecting AI origin.

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

Not specified in source record.

Additional detail

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/909/Cowden_v._Treasury__IRS_USA_20_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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