Sanction teardown · D. New Mexico, USA · 2026-05-01
Rasheem Carter, et al. v. UZGlobal LLC, et al.
What happened
In D. New Mexico, 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 (Case Law)Court identified the citation as non-existent and could not locate any corresponding case under variant spellings.
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Fabricated (Case Law)Court found no record of the cited Tenth Circuit decision and identified it as apparently non-existent.
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Fabricated (Case Law)Court determined the referenced Tenth Circuit citation could not be located and appears fabricated.
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Fabricated (Case Law)Court concluded the cited D. Colo. decision could not be found and appears to be a non-existent case.
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
Monetary Sanction; Bar Referral; CLE
Additional detail
First order to Show Cause is 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/2106/Carter_et_al_v_UZGlobal_LLC_USA_1_May_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).