What was hallucinated

Misrepresented: Case Law | Incorrect neutral citation C v C [2021] EWCA Civ 162 used to support unrelated propositions (totally without merit orders and amendment of pleading); the neutral citation actually relates to R (Children: Control of Court Documents). Court flagged this as a mis-citation suggestive of AI use. || Misrepresented: Case Law | Grace v Black Horse Limited cited as [2014] EWCA Civ 1091 when that neutral citation actually relates to R (on the application of Grace) v Secretary of State for the Home Department; the correct case was cited elsewhere but this instance was wrongly attributed. || Misrepresented: Case Law | Lloyds TSB Bank plc v Markandan & Uddin [2012] EWCA Civ 65 was deployed in relation to summary judgment with an unclear relevance; the same odd comment 'Your case contained disputed facts about re-entry' appeared, raising suspicion of AI-generated text. || Misrepresented: Case Law | Al Saud v Apex Global Management Limited [2014] EWCA Civ 1106 was cited in support of summary judgment despite lack of relevance; court treated this as another incorrect/irrelevant authority placed before it. || Misrepresented: Other | Authorities Document contained AI‑style, out‑of‑context language (e.g. 'Relevance: your client was a litigant in person' and repeated editorial comments), suggesting content produced by an AI assistant and not checked before filing.

Sanction teardown · County Court at Dudley, UK · 2026-04-23

Mrs Sabrena Rodney v Gee'z Micro Bar & Pitstop & Others

What happened

In County Court at Dudley, UK, 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)

Incorrect neutral citation C v C [2021] EWCA Civ 162 used to support unrelated propositions (totally without merit orders and amendment of pleading); the neutral citation actually relates to R (Children: Control of Court Documents). Court flagged this as a mis-citation suggestive of AI use.
Misrepresented (Case Law)

Grace v Black Horse Limited cited as [2014] EWCA Civ 1091 when that neutral citation actually relates to R (on the application of Grace) v Secretary of State for the Home Department; the correct case was cited elsewhere but this instance was wrongly attributed.
Misrepresented (Case Law)

Lloyds TSB Bank plc v Markandan & Uddin [2012] EWCA Civ 65 was deployed in relation to summary judgment with an unclear relevance; the same odd comment 'Your case contained disputed facts about re-entry' appeared, raising suspicion of AI-generated text.
Misrepresented (Case Law)

Al Saud v Apex Global Management Limited [2014] EWCA Civ 1106 was cited in support of summary judgment despite lack of relevance; court treated this as another incorrect/irrelevant authority placed before it.
Misrepresented (Other)

Authorities Document contained AI‑style, out‑of‑context language (e.g. 'Relevance: your client was a litigant in person' and repeated editorial comments), suggesting content produced by an AI assistant and not checked before filing.

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

SRA Referral

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/2137/Rodney.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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