What was hallucinated

Outdated Advice: Repealed Law | Plaintiff cited an incomplete/unspecified Westlaw entry attributed to the (nonexistent) Eastern District of Illinois; court could not find it and treated it as a hallucinated citation. || Fabricated: Case Law | Plaintiff cited Phipps v. Sears, Roebuck & Co., which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited Carberry v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited Cain v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent. || Fabricated: Case Law | Plaintiff cited a Miller decision purporting to be from the Eastern District of Illinois; court noted the Eastern District of Illinois no longer exists and could not verify the citation.

Sanction teardown · N.D. Illinois, USA · 2025-09-05

Poole v. Walmart, Inc.

What happened

In N.D. 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:

Outdated Advice (Repealed Law)

Plaintiff cited an incomplete/unspecified Westlaw entry attributed to the (nonexistent) Eastern District of Illinois; court could not find it and treated it as a hallucinated citation.
Fabricated (Case Law)

Plaintiff cited Phipps v. Sears, Roebuck & Co., which the court and defendant could not locate; court identified it as non-existent.
Fabricated (Case Law)

Plaintiff cited Carberry v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent.
Fabricated (Case Law)

Plaintiff cited Cain v. Chicago Transit Authority, which the court and defendant could not locate; court identified it as non-existent.
Fabricated (Case Law)

Plaintiff cited a Miller decision purporting to be from the Eastern District of Illinois; court noted the Eastern District of Illinois no longer exists and could not verify the citation.

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/783/Poole_v_Walmart_Inc.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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