Sanction teardown · DC Nebraska, USA · 2025-10-17
Mundy v. Clickstop, Inc.
What happened
In DC Nebraska, 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)Plaintiff cited a non-existent Nebraska case to support the discovery rule; court could not locate the authority.
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Fabricated (Case Law)Plaintiff cited a non-existent Nebraska decision regarding notice and commercial breach; court could not locate the authority.
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Misrepresented (Doctrinal Work)Plaintiff cited a Restatement provision with wording the court found to be hallucinated / inaccurate compared to the official Restatement text.
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Misrepresented (Case Law)Plaintiff used an incorrect/invalid Westlaw citation for a Nebraska Supreme Court case (led to unrelated material); the correct citation differs.
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Fabricated (Case Law)Plaintiff cited a Nebraska case that appears not to exist to support spoliation sanctions.
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Misrepresented (Case Law)Plaintiff attributed a proposition to Stones v. Sears that the case does not contain; the pincite actually addresses Magnuson‑Moss issues.
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Misrepresented (Case Law)Plaintiff relied on Lewy for the discovery rule and future-performance proposition though the 8th Cir. opinion does not stand for that proposition.
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False Quotes (Case Law)Plaintiff presented a sentence as a direct quote from the Levi Strauss order though it was a paraphrase; formatting error presented it as verbatim 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
Brief struck; Cert requirement; Monetary sanction; Bar Referral (monetary penalty: 2000 USD.)
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/1932/Mundy_v_Clickstop_Inc_USA_17_October_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).