What was hallucinated

False Quotes: Case Law | Plaintiff attributed the sentence "A conviction is not final until the completion of the direct appeal." to People v. Swafford; the Court found the quote does not appear in the opinion and noted cited passages contradict the proposition. || False Quotes: Case Law | Plaintiff attributed the sentence "A judgment is not final while an appeal of right remains pending." to People v. Kennedy; the Court found the quote does not appear in the opinion. || Fabricated: Case Law | Plaintiff cited "People v. Smith, 489 Mich. 292, 311 (2011)" for the proposition "A conviction pending on direct appeal is not a final adjudication." The Court was unable to locate the cited case and treated the citation as fabricated. || Fabricated: Case Law | Plaintiff cited "Savin v. City of Cleveland, 2022 WL 3715087 (6th Cir. 2022)"; the Court found the Westlaw citation pointed to an unrelated brief and could not locate a case by that name, indicating a likely mis-citation or fabrication.

Sanction teardown · E.D. Michigan, USA · 2026-03-27

Patrick C. Shaltry, I v. Brent Benzing, et al.

What happened

In E.D. Michigan, 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:

False Quotes (Case Law)

Plaintiff attributed the sentence "A conviction is not final until the completion of the direct appeal." to People v. Swafford; the Court found the quote does not appear in the opinion and noted cited passages contradict the proposition.
False Quotes (Case Law)

Plaintiff attributed the sentence "A judgment is not final while an appeal of right remains pending." to People v. Kennedy; the Court found the quote does not appear in the opinion.
Fabricated (Case Law)

Plaintiff cited "People v. Smith, 489 Mich. 292, 311 (2011)" for the proposition "A conviction pending on direct appeal is not a final adjudication." The Court was unable to locate the cited case and treated the citation as fabricated.
Fabricated (Case Law)

Plaintiff cited "Savin v. City of Cleveland, 2022 WL 3715087 (6th Cir. 2022)"; the Court found the Westlaw citation pointed to an unrelated brief and could not locate a case by that name, indicating a likely mis-citation or fabrication.

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/1924/Shaltry_v._Benzing_USA_27_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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