What was hallucinated

Fabricated: Legal Norm | The letters to the court quoted a non-existent statutory text presented as IR 12.37(5) (the 'Purported Text'); court found this text was invented by the firm's AI and placed in the letter without verification. || Fabricated: Legal Norm | AI asserted Rule 12.39 expressly provides for block transfer orders and power to make consequential directions; court found this attribution was false. || Misrepresented: Legal Norm | AI produced an incorrect account of section 173 of the Insolvency Act 1986, misstating which subsections apply and the circumstances and effects of release for liquidators. || Fabricated: Legal Norm | AI claimed the wording had been drawn from IR 12.37(8) (another fabricated attribution) when responding to the court's challenge; court found no such text exists in that paragraph.

Sanction teardown · Chancery, UK · 2026-05-22

Re an Office-Holder; Cork v Smith

What happened

In Chancery, UK, 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 (Legal Norm)

The letters to the court quoted a non-existent statutory text presented as IR 12.37(5) (the 'Purported Text'); court found this text was invented by the firm's AI and placed in the letter without verification.
Fabricated (Legal Norm)

AI asserted Rule 12.39 expressly provides for block transfer orders and power to make consequential directions; court found this attribution was false.
Misrepresented (Legal Norm)

AI produced an incorrect account of section 173 of the Insolvency Act 1986, misstating which subsections apply and the circumstances and effects of release for liquidators.
Fabricated (Legal Norm)

AI claimed the wording had been drawn from IR 12.37(8) (another fabricated attribution) when responding to the court's challenge; court found no such text exists in that paragraph.

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

Public admonishment; SRA Referral

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/2168/Cork_v._Smith_UK_22_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checker Back to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49 Sanctions-motion template