Sanction teardown · Ohio, USA · 2026-06-26
Morgan v. Jones
What happened
In Ohio, 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)Appellant cited 'City of Columbus v. Edwards-Bosh v. Tri-County Toyota, 10th Dist. Franklin No. 07AP-1042, 2008-Ohio-4320, ¶ 13-16'; court found no such case and the webcite pointed to an unrelated opinion.
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False Quotes (Case Law)Appellant quoted a passage about due process attributed to 'State ex rel. Ohio Turnpike Comm’n v. Indus. Comm., 109 Ohio St.3d 313, 2006-Ohio-2980, ¶ 22'; court found the citation misattributed (actual related opinion cited was a 2009 Tenth District opinion) and the quoted passage does not appear in the cited authorities.
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.
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/2522/Morgan_v._Jones_USA_26_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).