What was hallucinated

Fabricated: Case Law | Cited a non-existent case to support narrowing subpoenas; Court could locate no such case. || Fabricated: Case Law | Provided a citation purportedly from D. Neb. that does not exist (mis-cited/fictional). || Fabricated: Case Law | Cited an apparently fictitious Central District of California case rejecting requests for entire email accounts; Court could not locate it. || Misrepresented: Case Law | Authority exists but was cited as supporting rejection of expansive subpoenas involving email; Court found the case actually granted a motion to compel and does not support the claimed proposition. || Fabricated: Case Law | Cited a Northern District of Oklahoma decision that the Court could not locate; the referenced material instead pointed to unrelated Washington state health regulations. || Misrepresented: Case Law | Cited an existing S.D.N.Y. case for the proposition that a court may hear a motion to quash outside the district of compliance; Court found the case addresses amendment of a complaint, not venue for motions to quash. || False Quotes: Case Law | Quoted a passage attributed to the case that does not appear in the opinion; quotation was used to argue citation errors are not sanctionable but the case does not contain that language. || Misrepresented: Case Law | Cited an S.D.N.Y. decision that exists and involves subpoenas but does not support the specific proposition that this court may resolve a subpoena objection outside the district of compliance. || Fabricated: Case Law | Provided a citation that referred to an FDA safety report rather than a District of South Carolina case; Court could locate no such D.S.C. decision. || False Quotes: Case Law | Attributed a specific quotation about sanctions to the Supreme Court case, but the Court found the quotation does not appear in that opinion.

Sanction teardown · N.D. Oklahoma, USA · 2026-01-12

O. Gene Bicknell v. Richard M. Silanskas Jr., et al.

What happened

In N.D. Oklahoma, 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)

Cited a non-existent case to support narrowing subpoenas; Court could locate no such case.
Fabricated (Case Law)

Provided a citation purportedly from D. Neb. that does not exist (mis-cited/fictional).
Fabricated (Case Law)

Cited an apparently fictitious Central District of California case rejecting requests for entire email accounts; Court could not locate it.
Misrepresented (Case Law)

Authority exists but was cited as supporting rejection of expansive subpoenas involving email; Court found the case actually granted a motion to compel and does not support the claimed proposition.
Fabricated (Case Law)

Cited a Northern District of Oklahoma decision that the Court could not locate; the referenced material instead pointed to unrelated Washington state health regulations.
Misrepresented (Case Law)

Cited an existing S.D.N.Y. case for the proposition that a court may hear a motion to quash outside the district of compliance; Court found the case addresses amendment of a complaint, not venue for motions to quash.
False Quotes (Case Law)

Quoted a passage attributed to the case that does not appear in the opinion; quotation was used to argue citation errors are not sanctionable but the case does not contain that language.
Misrepresented (Case Law)

Cited an S.D.N.Y. decision that exists and involves subpoenas but does not support the specific proposition that this court may resolve a subpoena objection outside the district of compliance.
Fabricated (Case Law)

Provided a citation that referred to an FDA safety report rather than a District of South Carolina case; Court could locate no such D.S.C. decision.
False Quotes (Case Law)

Attributed a specific quotation about sanctions to the Supreme Court case, but the Court found the quotation does not appear in that opinion.

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

Warning

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/1303/Bicknell_v._Silanskas_USA_12_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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