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Nonnie Berg v. United Airlines, Inc. (3)

Court
D. Colorado
Jurisdiction
USA
Decided
2026-02-06
AI tool
Unidentified
Outcome
Filing restriction
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff's Motion for Extension cited a nonexistent Ninth Circuit case titled 'Kelley v. United States' with a fabricated reporter citation. || Fabricated: Case Law | Plaintiff's Motion for Extension cited a nonexistent 10th Circuit opinion 'United States v. Miller' with a fabricated Westlaw cite and date. || Misrepresented: Case Law | Plaintiff cited 'Moore v. City of Del City' but misstated the reporter information and attributed an 'excusable neglect' holding that the Moore opinion did not address.

Sanction teardown · D. Colorado, USA · 2026-02-06

Nonnie Berg v. United Airlines, Inc. (3)

What happened

In D. Colorado, 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:

  • Fabricated (Case Law)
    Plaintiff's Motion for Extension cited a nonexistent Ninth Circuit case titled 'Kelley v. United States' with a fabricated reporter citation.
  • Fabricated (Case Law)
    Plaintiff's Motion for Extension cited a nonexistent 10th Circuit opinion 'United States v. Miller' with a fabricated Westlaw cite and date.
  • Misrepresented (Case Law)
    Plaintiff cited 'Moore v. City of Del City' but misstated the reporter information and attributed an 'excusable neglect' holding that the Moore opinion did not address.

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

Filing restriction

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/1510/NONNIE_BERG_Plaintiff_v_UNITED_AIRLINES_INC_Defendants.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1510/NONNIE_BERG_Plaintiff_v_UNITED_AIRLINES_INC_Defendants.pdf

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