Sanction teardown · D. Utah, USA · 2026-03-23
Nicholas and Barbara Moulder v. Davis School District (on behalf of M.M.)
What happened
In D. Utah, 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)Plaintiffs' briefing cited a non-existent case as legal authority; court found the case did not exist and counsel admitted failing to verify after using AI.
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Fabricated (Case Law)Plaintiffs' briefing cited a second non-existent case as legal authority; court determined it was fabricated and counsel accepted responsibility for not verifying.
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False Quotes (Case Law)Plaintiffs' briefing included a non-existent quotation attributed to authority; court determined the quote did not exist and was not verified by counsel after use of AI.
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
CLE; Monetary Sanction (monetary penalty: 1525 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/1836/Moulder_v._Davis_School_USA_23_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).