Sanction teardown · AC Illinois, USA · 2025-11-24
Pletcher v. Village of Libertyville Police Pension Board
What happened
In AC 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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Fabricated (Exhibits & Submissions)Plaintiff cited non-existent record page numbers and referenced exhibits (A-F) that were never introduced into the administrative record; court noted these citations to the record do not exist.
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Fabricated (Case Law)Plaintiff cited a nonexistent case and quoted a favorable holding that does not exist; court found the case fictitious.
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Fabricated (Case Law)Plaintiff cited a nonexistent case as authority for a rule on selective medical opinions; court found the citation fictitious.
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Fabricated (Case Law)Plaintiff cited a nonexistent case claiming recognition of cumulative stress effects on cardiovascular health; court found citation fictitious.
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Fabricated (Case Law)Plaintiff cited a nonexistent case to argue that a 14-month delay violated a statutory timeframe; court found the citation fictitious.
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Fabricated (Case Law)Plaintiff cited a nonexistent case on delay in issuing rulings; court found the case does not exist and plaintiff later conceded it was inapplicable.
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False Quotes (Case Law)Plaintiff attributed a favorable holding to Bowlin that the case does not contain; court determined the quoted language is not in Bowlin.
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False Quotes (Case Law)Plaintiff quoted Johnson as stating inability to comply with treatment does not negate disability; court found Johnson does not support that statement.
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False Quotes (Case Law)Plaintiff quoted Knight as holding that persistence despite treatment does not infer non-compliance; court found Knight does not contain that language.
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False Quotes (Case Law)Plaintiff attributed a broad rebuke of selective expert reliance to Roszak that the case does not support; court found the quote misleading.
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False Quotes (Case Law)Plaintiff claimed Jones supports a finding about shift work and cardiovascular harm; court found Jones does not address hypertension or related conditions.
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False Quotes (Case Law)Plaintiff attributed a genetics-related holding to Johnston that the case does not contain; court found the quoted language absent from Johnston.
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
Plaintiff's appellate brief stricken and appeal dismissed
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/1368/Pletcher_v_Village_of_Libertyville_Police_Pension_Board.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).