Sanction teardown · S.D. Florida, USA · 2026-02-04
Mitchell Taylor Button & Dusty Button v. Sigrid McCawley
What happened
In S.D. Florida, 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:
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Fabricated (Case Law)Plaintiffs cited In re: Marriage of Smith, 195 Cal. App. 4th 1007, 1018 (2011), which the court identified as a non-existent authority as presented.
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False Quotes (Case Law)Plaintiffs attributed the quotation "Dismissal based on a legal defense does not equate to frivolity." to Parekh; court found Parekh contains no such language.
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False Quotes (Case Law)Plaintiffs attributed a quotation about use of confidential information to In re Shell Oil Refinery; court found the quoted material is not in that case.
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Fabricated (Case Law)Plaintiffs cited Lopez v. Bank of Am., N.A., No. 14-cv-2524, 2016 WL 4131149 (N.D. Cal. Aug. 3, 2016), which the court found does not exist as cited.
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Fabricated (Case Law)Plaintiffs cited Harris v. City of Auburn, 2018 WL 3329858 (M.D. Ala. July 6, 2018), which the court determined was a mis-citation (the cited decision did not exist as presented).
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Fabricated (Case Law)Plaintiffs cited Avery v. Ward, 2014 WL 4748452, at *3 (S.D. Ala. Sept. 23, 2014), which the court found does not exist as cited.
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False Quotes (Case Law)Plaintiffs quoted language attributed to Schwartz v. Millon Air, Inc., 341 F.3d 1220, 1225 (11th Cir. 2003) that does not appear in that opinion; court found the quotation fabricated/misattributed.
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Misrepresented (Exhibits & Submissions)Plaintiffs claimed the magistrate's R&R contained language calling them 'serial litigants' and accusing them of filing to 'harass' and being 'retaliatory'; the court found those characterizations do not appear in the R&R.
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
Show Cause Order; Order to certify review of citations
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/1456/Button_v._Mccawley_USA_4_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).