Sanction teardown · CA Illinois, USA · 2026-02-09
[Plaintiff] v. Webb Chevrolet, Inc., et al.
What happened
In CA Illinois, 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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False Quotes (Case Law)Plaintiff attributed a specific quote to Fox v. Heiman that does not appear in that opinion; court noted Fox does not mention section 2-619 or contain the quoted language.
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False Quotes (Case Law)Plaintiff asserted Concepcion supports limitations on arbitration protecting consumer claims; court observed Concepcion does not include the propositions plaintiff attributed to it.
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False Quotes (Case Law)Plaintiff claimed Kinkel and Gallagher stand for broad public-policy limits on arbitration clauses; court found neither case supports the sweeping propositions plaintiff attributed to them.
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Fabricated (Case Law)Plaintiff cited a nonexistent Illinois opinion; court searched and found no case by this name and the cited volume/page corresponded to an unrelated criminal opinion.
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Fabricated (Case Law)Plaintiff cited a nonexistent case title/citation; court found the actual opinion at that citation was a different case and no 'Sears v. Illinois Central Savings & Loan' exists.
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Fabricated (Case Law)Plaintiff cited a case by name and citation that do not exist in Illinois or elsewhere; court's search returned no such authority.
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Fabricated (Case Law)Plaintiff cited a nonexistent opinion and attributed a specific holding; court found no such case or holding at the citation provided.
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Fabricated (Case Law)Plaintiff cited a case title/citation that matched other unrelated opinions; court found no support for the claimed arbitration-related holding.
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False Quotes (Case Law)Plaintiff quoted language purportedly from Smith v. Airoom that does not appear in the opinion; court found the quoted language and the asserted principles absent from Smith.
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False Quotes (Case Law)Plaintiff attributed a holding to Keefe that the case does not contain (re: section 2-619 not a responsive pleading); court found Keefe does not contain the quoted language or discuss section 2-619.
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
Order to show cause
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.
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Source: https://www.damiencharlotin.com/documents/1475/Palsen_v._Chevrolet_USA_9_February_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).