What was hallucinated

Misrepresented: Case Law | The AI report asserted that Church of the Lukumi Babalu Aye v. City of Hialeah supports the plaintiff's standing to assert her church's rights; the court noted Lukumi does not discuss standing. || Fabricated: Case Law | The AI report contained various incorrect or nonexistent case citations and factitious references; the court described the Report as unreliable and declined to consider it.

Details

The Court refused to consider a pro se plaintiff's AI-generated "Legal Analysis Report" produced with ChatGPT-4o because it contained incorrect and factitious citations and misstatements of law; the Rule 60(b) motion was denied.

Sanction teardown · E.D. Michigan, USA · 2026-01-16

Rev. Heidi Grossman Lepp v. Conrad Mallett, Jr., et al.

What happened

In E.D. Michigan, USA, a filing relied on OpenAI ChatGPT-4o to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

The AI report asserted that Church of the Lukumi Babalu Aye v. City of Hialeah supports the plaintiff's standing to assert her church's rights; the court noted Lukumi does not discuss standing.
Fabricated (Case Law)

The AI report contained various incorrect or nonexistent case citations and factitious references; the court described the Report as unreliable and declined to consider it.

Which AI tool

OpenAI ChatGPT-4o. 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

Arguments ignored

Additional detail

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/1363/Heidi_Grossman_Lepp_v_Conrad_Mallett_Jr_et_al_USA_16_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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