Sanction teardown · W.D. Tennessee, USA · 2026-06-02
Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al.
What happened
In W.D. Tennessee, 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)Plaintiff cited 'Press v. Vanderbilt University' for actual malice; court could find no such case and the citation led to an SEC No-Action letter instead.
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Fabricated (Case Law)Plaintiff cited 'Thornbury v. Madison Cnty., 242 F. Supp. 3d 851, 860 (W.D. Tenn. 2017)'; court found no matching opinion and identified only an unrelated Jackson v. Lew, 242 F. Supp. 3d 850 (W.D. Mo. 2017).
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False Quotes (Case Law)Plaintiff attributed a quotation to Lazy Seven Coal Sales but the quoted language does not appear in the cited opinion.
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False Quotes (Case Law)Plaintiff attributed a quotation to White v. McBride that the court determined does not exist in that opinion.
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Misrepresented (Case Law)Plaintiff cited Seaton v. Lawson Chevrolet-Mazda, a real case, for the proposition that a fiduciary duty of loyalty exists independent of negligence, but the case addressed punitive damages in a car sale and is unrelated to fiduciary duties.
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Misrepresented (Case Law)Plaintiff cited Hoover v. Langston Equip. Assocs., Inc., 958 F.2d 742 (6th Cir. 1992) as supporting that no authority imposes fiduciary duties from a client to a lawyer; court noted Hoover did not address attorney-client fiduciary duty and was misapplied.
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Misrepresented (Case Law)Plaintiff cited Whitehaven Cmty. Baptist Church v. Holloway for the proposition about constructive trust and unjust enrichment being unavailable where an express contract governs; court found the cited opinion does not reference constructive trusts and was misused.
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Misrepresented (Case Law)Plaintiff cited Givens v. Mullikin, 75 S.W.3d 383 (Tenn. 2002) for a proposition about attorney immunity and disloyalty, but the case's holding concerns vicarious liability for an attorney and does not support the cited proposition.
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
Adverse Costs Order; Bar Referral (monetary penalty: 1 USD.)
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/2257/Reaves_Law_Firm_v._Baker_USA_2_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).