What was hallucinated

Fabricated: Case Law | Plaintiff cited as controlling authority a non-existent S.D. Ohio case. || Fabricated: Case Law | Plaintiff asserted the Court relied on a case that does not appear to exist; the Court actually cited In re McDonald. || False Quotes: Case Law | Plaintiff quoted the phrase “uncompensable by money” from the case, but the phrase does not appear and the case concerns Sherman Act, not civil rights. || False Quotes: Case Law | Plaintiff provided a purported quote from the case that does not appear in that decision. || False Quotes: Case Law | Plaintiff’s filing quoted six cases, but none contained the cited language. || Fabricated: Case Law | Plaintiff cited as controlling authority a case the court could not find exists. || False Quotes: Case Law | Plaintiff attributed a quotation to the case, but the quoted language does not appear there.

Details

"Compounding the problem, what generative AI lacks in precision, it more than makes up for in speed. Litigants who simply file the material that AI tools generate, without carefully reviewing it first for accuracy, have the potential to swamp courts with what appear at first glance to be legal arguments built on law and precedent, but which are in fact nothing of the sort. And not only are these problems in their own right, but they also heighten the two concerns the Court highlighted above—that defendants will be forced to spend more time and incur more costs parsing through copious baseless filings to defend an action, and that Courts will waste precious time doing the same in ruling on motions and moving matters along."(Plaintiff acknowledged use of ChatGPT in a subsequent filing)Plaintiff was eventually designated as vexatious litigant and his case dismissed with prejudice.

Sanction teardown · S.D. Ohio, USA · 2025-07-03

Muhammad v. Gap Inc.

What happened

In S.D. Ohio, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Plaintiff cited as controlling authority a non-existent S.D. Ohio case.
Fabricated (Case Law)

Plaintiff asserted the Court relied on a case that does not appear to exist; the Court actually cited In re McDonald.
False Quotes (Case Law)

Plaintiff quoted the phrase “uncompensable by money” from the case, but the phrase does not appear and the case concerns Sherman Act, not civil rights.
False Quotes (Case Law)

Plaintiff provided a purported quote from the case that does not appear in that decision.
False Quotes (Case Law)

Plaintiff’s filing quoted six cases, but none contained the cited language.
Fabricated (Case Law)

Plaintiff cited as controlling authority a case the court could not find exists.
False Quotes (Case Law)

Plaintiff attributed a quotation to the case, but the quoted language does not appear there.

Which AI tool

ChatGPT. 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

OSC

Additional detail

"Compounding the problem, what generative AI lacks in precision, it more than makes up for in speed. Litigants who simply file the material that AI tools generate, without carefully reviewing it first for accuracy, have the potential to swamp courts with what appear at first glance to be legal arguments built on law and precedent, but which are in fact nothing of the sort. And not only are these problems in their own right, but they also heighten the two concerns the Court highlighted above—that defendants will be forced to spend more time and incur more costs parsing through copious baseless filings to defend an action, and that Courts will waste precious time doing the same in ruling on motions and moving matters along."(Plaintiff acknowledged use of ChatGPT in a subsequent filing)Plaintiff was eventually designated as vexatious litigant and his case dismissed with prejudice.

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/700/Muhammad_v_Gap_Inc.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).