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Richard Paul Smith v. Verra Mobility Corporation et al.

Court
M.D. Florida
Jurisdiction
USA
Decided
2026-05-01
AI tool
ChatGPT
Outcome
Order to Notify Client
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | School Board relied on 'Morgulis v. BusPatrol Am., LLC, 2020 WL 1923164, at *8–9 (E.D.N.Y. Apr. 21, 2020)' as authority; Court concluded the case does not exist as cited and that the School Board mis-cited/misidentified the authority. || Fabricated: Case Law | School Board cited a non-existent decision 'Gonzalez v. City of Coral Gables, 2018 WL 2392077 (S.D. Fla. May 25, 2018)'; Court found the citation does not appear to exist. || Misrepresented: Case Law | School Board brief represented Pincus as reaffirming that Florida law bars unjust enrichment/recovery where a payer knowingly elects to pay; Court noted Pincus did not discuss the voluntary payment doctrine as represented. || Fabricated: Case Law | School Board cited a non-existent decision 'Abreu v. City of Miami Beach, 2021 WL 3625049 (S.D. Fla. Aug. 16, 2021)'; Court found the citation does not appear to exist.

Details

Order to Show Cause is here.

Sanction teardown · M.D. Florida, USA · 2026-05-01

Richard Paul Smith v. Verra Mobility Corporation et al.

What happened

In M.D. Florida, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    School Board relied on 'Morgulis v. BusPatrol Am., LLC, 2020 WL 1923164, at *8–9 (E.D.N.Y. Apr. 21, 2020)' as authority; Court concluded the case does not exist as cited and that the School Board mis-cited/misidentified the authority.
  • Fabricated (Case Law)
    School Board cited a non-existent decision 'Gonzalez v. City of Coral Gables, 2018 WL 2392077 (S.D. Fla. May 25, 2018)'; Court found the citation does not appear to exist.
  • Misrepresented (Case Law)
    School Board brief represented Pincus as reaffirming that Florida law bars unjust enrichment/recovery where a payer knowingly elects to pay; Court noted Pincus did not discuss the voluntary payment doctrine as represented.
  • Fabricated (Case Law)
    School Board cited a non-existent decision 'Abreu v. City of Miami Beach, 2021 WL 3625049 (S.D. Fla. Aug. 16, 2021)'; Court found the citation does not appear to exist.

Which AI tool

ChatGPT. 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

Order to Notify Client

Additional detail

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/2107/Smith_v._Verra_USA_1_May_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2107/Smith_v._Verra_USA_1_May_2025.pdf

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