What was hallucinated

False Quotes: Case Law | Plaintiff attributed a quote to Long v. SEPTA that does not appear in the Long opinion; court treated this as a phantom/erroneous quote identified by defense counsel. || False Quotes: Case Law | Plaintiff quoted Burlington Coat Factory as stating the futility standard is 'identical' to the Rule 12(b)(6) standard, whereas the Third Circuit used 'the same' — an inaccurate quotation. || False Quotes: Case Law | Plaintiff inserted brackets in the Supreme Court quote 'freely give[n]' from Foman v. Davis though the brackets/alteration do not appear in the original quotation.

Sanction teardown · W.D. Pennsylvania, USA · 2025-12-05

Mullins v. Duquesne University of the Holy Spirit

What happened

In W.D. Pennsylvania, 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:

False Quotes (Case Law)

Plaintiff attributed a quote to Long v. SEPTA that does not appear in the Long opinion; court treated this as a phantom/erroneous quote identified by defense counsel.
False Quotes (Case Law)

Plaintiff quoted Burlington Coat Factory as stating the futility standard is 'identical' to the Rule 12(b)(6) standard, whereas the Third Circuit used 'the same' — an inaccurate quotation.
False Quotes (Case Law)

Plaintiff inserted brackets in the Supreme Court quote 'freely give[n]' from Foman v. Davis though the brackets/alteration do not appear in the original quotation.

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

Reply struck; Order to disclose AI use

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/1176/Mullins_v._DUQUESNE_UNIVERSITY_OF_the_Holy_Spirit_USA_5_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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