What was hallucinated

False Quotes: Case Law | Brief attributed: '[T]he maritime lien includes the principal debt, interest and reasonable attorney's fees, where provided for in the contract.' to Crescent Towing & Salvage Co. v. M/V ANAX (40 F.3d 741, 744 (5th Cir. 1994)); court found the quoted language absent from that opinion and not located elsewhere. || False Quotes: Case Law | Brief attributed: 'The term "necessaries" includes the contract price, including interest if agreed or customary.' to General Elec. Credit Corp. v. Drill Ship Mission Exploration (668 F.2d 811, 815 (5th Cir. 1982)); court found the quoted language absent from that opinion and not located elsewhere.

Details

In a later order, the court declined to order any sanctions in "light of counsel's acknowledgment of the fact that the quotations at issue were not independently verified against the actual opinions and acceptance of responsibility and the remedial measures subsequently put in place to avoid a repetition of the errors "

Sanction teardown · S.D. New York, USA · 2025-09-26

Pennantia v. Rose Cay Maritime

What happened

In S.D. New York, 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)

Brief attributed: '[T]he maritime lien includes the principal debt, interest and reasonable attorney's fees, where provided for in the contract.' to Crescent Towing & Salvage Co. v. M/V ANAX (40 F.3d 741, 744 (5th Cir. 1994)); court found the quoted language absent from that opinion and not located elsewhere.
False Quotes (Case Law)

Brief attributed: 'The term "necessaries" includes the contract price, including interest if agreed or customary.' to General Elec. Credit Corp. v. Drill Ship Mission Exploration (668 F.2d 811, 815 (5th Cir. 1982)); court found the quoted language absent from that opinion and not located elsewhere.

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

No sanctions

Additional detail

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/1017/Pennantia_v._Rose_Cay_Maritime_USA_26_August_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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