What was hallucinated

Fabricated: Case Law | Court found no record of Turner v. Palo Alto Networks, Inc., 2023 WL 4567762 (E.D. Tex. 2023); the citation appears nonexistent and was identified as an AI-generated hallucination. || Fabricated: Case Law | Court found no In re Caterpillar Inc. decision that matches the cited authority or supports the plaintiff's proposition; the particular citation (67 F.3d 815 (5th Cir. 1995)) does not correspond to a controlling or supportive Fifth Circuit decision as used by plaintiff. || Misrepresented: Case Law | Plaintiff cited Waguespack v. Medtronic, Inc., 2020 WL 8673953, but the court located Waguespack at 185 F. Supp. 3d 916 (M.D. La. 2016) and the Westlaw link provided actually pointed to Renner v. Morris, 2020 WL 8673953; the authority and quoted language were misattributed and do not support the claimed proposition in the Fifth Circuit.

Sanction teardown · E.D. Texas, USA · 2025-11-18

Moorehead v. Goodwill Industries of Northeast Texas

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)

Court found no record of Turner v. Palo Alto Networks, Inc., 2023 WL 4567762 (E.D. Tex. 2023); the citation appears nonexistent and was identified as an AI-generated hallucination.
Fabricated (Case Law)

Court found no In re Caterpillar Inc. decision that matches the cited authority or supports the plaintiff's proposition; the particular citation (67 F.3d 815 (5th Cir. 1995)) does not correspond to a controlling or supportive Fifth Circuit decision as used by plaintiff.
Misrepresented (Case Law)

Plaintiff cited Waguespack v. Medtronic, Inc., 2020 WL 8673953, but the court located Waguespack at 185 F. Supp. 3d 916 (M.D. La. 2016) and the Westlaw link provided actually pointed to Renner v. Morris, 2020 WL 8673953; the authority and quoted language were misattributed and do not support the claimed proposition in the Fifth Circuit.

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/1054/Moorehead_v._Goodwill_Industry_USA_18_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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