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Multiphone Latin America v. Millicom International Cellular

Court
S.D. Florida
Jurisdiction
USA
Decided
2025-08-28
AI tool
Implied
Outcome
Referral to District Ad Hoc Committee and the Florida Bar for investigation
Monetary penalty
None reported

What was hallucinated

Misrepresented: Case Law | Response cites at least four existing cases for propositions those opinions do not discuss (e.g., citing Morrison v. Nissan Motor Co., 601 F.2d 139 for an unrelated point); Court identified misapplication of authority. || False Quotes: Case Law | Proposed Sur-Reply and Response attribute quoted language to Cohen v. Cooper (20 So. 3d 453) that does not appear in that opinion; Court identified the misquote. || False Quotes: Case Law | Counsel presented quotes drawn from Westlaw Keynotes as if they were verbatim text from opinions (examples include Rollins and Stewart), a misrepresentation the Court noted. || Fabricated: Case Law | Response cites 'Metropolitan Dade County v. Dyer, 315 So. 2d 442, 444 (Fla. 3d DCA 1975)', which the Court found appears not to exist. || Fabricated: Case Law | Response cites 'QBE Ins. Corp. v. Dome Constr. Corp., 10 So. 3d 676, 678 (Fla. 4th DCA 2009)', another authority the Court determined appears to be nonexistent.

Sanction teardown · S.D. Florida, USA · 2025-08-28

Multiphone Latin America v. Millicom International Cellular

What happened

In S.D. Florida, 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:

  • Misrepresented (Case Law)
    Response cites at least four existing cases for propositions those opinions do not discuss (e.g., citing Morrison v. Nissan Motor Co., 601 F.2d 139 for an unrelated point); Court identified misapplication of authority.
  • False Quotes (Case Law)
    Proposed Sur-Reply and Response attribute quoted language to Cohen v. Cooper (20 So. 3d 453) that does not appear in that opinion; Court identified the misquote.
  • False Quotes (Case Law)
    Counsel presented quotes drawn from Westlaw Keynotes as if they were verbatim text from opinions (examples include Rollins and Stewart), a misrepresentation the Court noted.
  • Fabricated (Case Law)
    Response cites 'Metropolitan Dade County v. Dyer, 315 So. 2d 442, 444 (Fla. 3d DCA 1975)', which the Court found appears not to exist.
  • Fabricated (Case Law)
    Response cites 'QBE Ins. Corp. v. Dome Constr. Corp., 10 So. 3d 676, 678 (Fla. 4th DCA 2009)', another authority the Court determined appears to be nonexistent.

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

Referral to District Ad Hoc Committee and the Florida Bar for investigation

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/729/Multiphone_Latin_v._Millicom_International_Cellular.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/729/Multiphone_Latin_v._Millicom_International_Cellular.pdf

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