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Prososki v. Regan

Court
SC Nebraska
Jurisdiction
USA
Decided
2026-03-20
AI tool
Unidentified
Outcome
Appellant's brief stricken; appellant's appeal dismissed; Bar referral; Suspension
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Brief cites 'Miller v. Miller, 227 Neb. 71, 416 N.W.2d 358 (1987)' and attributes quotations/holdings that the court determined are fictitious; the citation refers to a nonexistent authority as used. || Misrepresented: Case Law | Brief attributes quotations and holdings to Bergmeier v. Bergmeier that do not appear in that opinion and misstates the case's holdings. || Fabricated: Case Law | Brief repeatedly cited 'Kennedy v. Kennedy, 27 Neb. App. 510, 934 N.W.2d 57 (2019)' and included block quotations and holdings not present; the cited unreported memorandum opinion does not contain the quoted language or the purported holding. || False Quotes: Legal Norm | Brief purports to quote Neb. Rev. Stat. § 43-2923 as stating a specific policy favoring frequent contact with both parents; the statute does not contain the quoted language and was misquoted. || False Quotes: Case Law | Brief attributes a quoted principle about notice of issues to Simons v. Simons that does not appear in the opinion; the quoted language cannot be found in the case and the case does not support the proposition advanced.

Details

The suspension was later reported by local media (see, e.g., here).

Sanction teardown · SC Nebraska, USA · 2026-03-20

Prososki v. Regan

What happened

In SC Nebraska, 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:

  • Fabricated (Case Law)
    Brief cites 'Miller v. Miller, 227 Neb. 71, 416 N.W.2d 358 (1987)' and attributes quotations/holdings that the court determined are fictitious; the citation refers to a nonexistent authority as used.
  • Misrepresented (Case Law)
    Brief attributes quotations and holdings to Bergmeier v. Bergmeier that do not appear in that opinion and misstates the case's holdings.
  • Fabricated (Case Law)
    Brief repeatedly cited 'Kennedy v. Kennedy, 27 Neb. App. 510, 934 N.W.2d 57 (2019)' and included block quotations and holdings not present; the cited unreported memorandum opinion does not contain the quoted language or the purported holding.
  • False Quotes (Legal Norm)
    Brief purports to quote Neb. Rev. Stat. § 43-2923 as stating a specific policy favoring frequent contact with both parents; the statute does not contain the quoted language and was misquoted.
  • False Quotes (Case Law)
    Brief attributes a quoted principle about notice of issues to Simons v. Simons that does not appear in the opinion; the quoted language cannot be found in the case and the case does not support the proposition advanced.

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

Appellant's brief stricken; appellant's appeal dismissed; Bar referral; Suspension

Additional detail

The suspension was later reported by local media (see, e.g., here).

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/1699/N00013081PUB.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1699/N00013081PUB.pdf

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