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Rashonna Moore v. City of Del City

Court
10th Cir. CA
Jurisdiction
USA
Decided
2025-12-03
AI tool
Implied
Outcome
District court judgment affirmed; alternatively appeal dismissed as a sanction for misuse of GenAI; Future disclosure of GenAI use and verification of citations ordered, under penalty of perjury.
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Eleven case citations in Moore's appellate brief could not be located on Westlaw; court concluded they appear fabricated and ordered Moore to produce copies or explain their origin. || Fabricated: Case Law | Moore cited 'Cohen v. United States, 201 F.3d 109'; court found this citation fabricated (the reporter page corresponds to Kalwasinski v. Morse, 201 F.3d 103) and treated it as an AI-generated hallucination. || Misrepresented: Case Law | Moore misrepresented Hudson v. Michigan, 547 U.S. 586 (2006), claiming it supported a particular principle; court found the representation inaccurate and that the case did not state the proposition she attributed to it. || Misrepresented: Case Law | Moore cited Gilday v. Mecosta County, 124 F.3d 760 (6th Cir. 1997) as supporting 'equitable access principles'; court found Gilday does not contain or use that language or principle and deemed the citation mischaracterized.

Sanction teardown · 10th Cir. CA, USA · 2025-12-03

Rashonna Moore v. City of Del City

What happened

In 10th Cir. CA, 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)
    Eleven case citations in Moore's appellate brief could not be located on Westlaw; court concluded they appear fabricated and ordered Moore to produce copies or explain their origin.
  • Fabricated (Case Law)
    Moore cited 'Cohen v. United States, 201 F.3d 109'; court found this citation fabricated (the reporter page corresponds to Kalwasinski v. Morse, 201 F.3d 103) and treated it as an AI-generated hallucination.
  • Misrepresented (Case Law)
    Moore misrepresented Hudson v. Michigan, 547 U.S. 586 (2006), claiming it supported a particular principle; court found the representation inaccurate and that the case did not state the proposition she attributed to it.
  • Misrepresented (Case Law)
    Moore cited Gilday v. Mecosta County, 124 F.3d 760 (6th Cir. 1997) as supporting 'equitable access principles'; court found Gilday does not contain or use that language or principle and deemed the citation mischaracterized.

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

District court judgment affirmed; alternatively appeal dismissed as a sanction for misuse of GenAI; Future disclosure of GenAI use and verification of citations ordered, under penalty of perjury.

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/1143/Moore_v._City_of_Del_City_USA_3_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1143/Moore_v._City_of_Del_City_USA_3_December_2025.pdf

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