What was hallucinated

Misrepresented: Case Law | Plaintiff cited Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976), and SEC v. W.J. Howey Co., 328 U.S. 293 (1946), to claim a federal common-law fiduciary duty supports a common-law private right of action; the Court held neither case supports that proposition and each addresses statutory securities laws. || Misrepresented: Legal Norm | Plaintiff asserted a "federal common law of securities" as a basis for suit; the Court held no such federal common law exists and that securities law is governed by federal statutes. || Misrepresented: Legal Norm | Plaintiff argued the Declaratory Judgment Act itself confers federal-question jurisdiction; the Court rejected this, noting the Act alone cannot create jurisdiction. || Misrepresented: Legal Norm | Plaintiff claimed his accounting and fraudulent concealment claims are "federalized" via constructive trust principles and thus present a federally cognizable injury; the Court held these are state-law remedies/claims and do not create federal-question jurisdiction. || Misrepresented: Legal Norm | Plaintiff contended that references to federal regulations and constitutional issues in his complaint establish a substantial federal question; the Court found those references not critical to resolving his claims and insufficient for federal jurisdiction.

Details

AI UseThe court stated that “Moales may have used artificial intelligence in drafting his submissions,” citing widespread concerns over AI hallucination. It noted that several citations in his complaint and show-cause response were plainly incorrect or irrelevant. While Moales did not admit AI use, the court cited Strong v. Rushmore Loan Mgmt. Servs., 2025 WL 100904 (D. Neb.) and Mata v. Avianca to contextualize its concern.Hallucination DetailsCited Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976), and S.E.C. v. W.J. Howey Co., 328 U.S. 293 (1946) as supporting the existence of a federal common law fiduciary duty—an inaccurate legal proposition. The court characterized such misuses as “the norm rather than the exception” in Moales’s submissions. It stopped short of identifying all misused authorities but made clear that the inaccuracies were pervasive.Ruling/SanctionThe complaint was dismissed for lack of subject matter jurisdiction under Rule 12(h)(3). Moales was permitted to file an amended complaint by May 28, 2025, but was warned that future filings must be factually and legally accurate. The court declined to reach the venue issue or impose immediate sanctions but warned Moales that misrepresentation of law may violate Rule 11.Key Judicial ReasoningThe court found no basis for federal question jurisdiction and rejected Moales’s reliance on the Declaratory Judgment Act, constructive trust theories, and a nonexistent “federal common law of securities.” It also held that Moales failed to plausibly allege the amount in controversy necessary for diversity jurisdiction.

Sanction teardown · D. Connecticut, USA · 2025-04-30

Moales v. Land Rover Cherry Hill

What happened

In D. Connecticut, 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 Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976), and SEC v. W.J. Howey Co., 328 U.S. 293 (1946), to claim a federal common-law fiduciary duty supports a common-law private right of action; the Court held neither case supports that proposition and each addresses statutory securities laws.
Misrepresented (Legal Norm)

Plaintiff asserted a "federal common law of securities" as a basis for suit; the Court held no such federal common law exists and that securities law is governed by federal statutes.
Misrepresented (Legal Norm)

Plaintiff argued the Declaratory Judgment Act itself confers federal-question jurisdiction; the Court rejected this, noting the Act alone cannot create jurisdiction.
Misrepresented (Legal Norm)

Plaintiff claimed his accounting and fraudulent concealment claims are "federalized" via constructive trust principles and thus present a federally cognizable injury; the Court held these are state-law remedies/claims and do not create federal-question jurisdiction.
Misrepresented (Legal Norm)

Plaintiff contended that references to federal regulations and constitutional issues in his complaint establish a substantial federal question; the Court found those references not critical to resolving his claims and insufficient for federal jurisdiction.

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

Plaintiff warned to ensure accuracy of future submissions

Additional detail

AI UseThe court stated that “Moales may have used artificial intelligence in drafting his submissions,” citing widespread concerns over AI hallucination. It noted that several citations in his complaint and show-cause response were plainly incorrect or irrelevant. While Moales did not admit AI use, the court cited Strong v. Rushmore Loan Mgmt. Servs., 2025 WL 100904 (D. Neb.) and Mata v. Avianca to contextualize its concern.Hallucination DetailsCited Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976), and S.E.C. v. W.J. Howey Co., 328 U.S. 293 (1946) as supporting the existence of a federal common law fiduciary duty—an inaccurate legal proposition. The court characterized such misuses as “the norm rather than the exception” in Moales’s submissions. It stopped short of identifying all misused authorities but made clear that the inaccuracies were pervasive.Ruling/SanctionThe complaint was dismissed for lack of subject matter jurisdiction under Rule 12(h)(3). Moales was permitted to file an amended complaint by May 28, 2025, but was warned that future filings must be factually and legally accurate. The court declined to reach the venue issue or impose immediate sanctions but warned Moales that misrepresentation of law may violate Rule 11.Key Judicial ReasoningThe court found no basis for federal question jurisdiction and rejected Moales’s reliance on the Declaratory Judgment Act, constructive trust theories, and a nonexistent “federal common law of securities.” It also held that Moales failed to plausibly allege the amount in controversy necessary for diversity jurisdiction.

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/346/Moales_v._Land_Rover_Cherry_Hill_D._Connecticut_April_30_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).