What was hallucinated

Fabricated: Case Law | Plaintiff cited a non-existent M.D. Fla. decision as Baker v. BDO Seidman, LLP; court notes plaintiff conceded the citation was incorrect and the real case was a non-binding N.D. Cal. decision not involving bankruptcy. || False Quotes: Case Law | Plaintiff attributed a sentence about remand promoting judicial economy and discouraging forum shopping to Republic Reader’s; the court found the quotation does not exist in the opinion. || False Quotes: Case Law | Plaintiff quoted Eastus as requiring courts to weigh in favor of remand in non-core state law proceedings; the court found the quotation does not exist and noted Eastus did not involve bankruptcy. || Misrepresented: Case Law | Plaintiff cited Kircher for the burden of establishing federal jurisdiction on the removing party; the court explained Kircher addressed appellate review of remand orders and footnote 12 was unrelated. || Misrepresented: Case Law | Plaintiff asserted Hirsch reaffirmed that malpractice and fiduciary duty claims are generally non-core and belong in state court; the court noted plaintiff conceded this was inaccurate, with only state-law application being similar.

Sanction teardown · M.D. Florida, USA · 2025-07-28

Robbins v. Martin Law Firm, P.L.

What happened

In M.D. Florida, 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)

Plaintiff cited a non-existent M.D. Fla. decision as Baker v. BDO Seidman, LLP; court notes plaintiff conceded the citation was incorrect and the real case was a non-binding N.D. Cal. decision not involving bankruptcy.
False Quotes (Case Law)

Plaintiff attributed a sentence about remand promoting judicial economy and discouraging forum shopping to Republic Reader’s; the court found the quotation does not exist in the opinion.
False Quotes (Case Law)

Plaintiff quoted Eastus as requiring courts to weigh in favor of remand in non-core state law proceedings; the court found the quotation does not exist and noted Eastus did not involve bankruptcy.
Misrepresented (Case Law)

Plaintiff cited Kircher for the burden of establishing federal jurisdiction on the removing party; the court explained Kircher addressed appellate review of remand orders and footnote 12 was unrelated.
Misrepresented (Case Law)

Plaintiff asserted Hirsch reaffirmed that malpractice and fiduciary duty claims are generally non-core and belong in state court; the court noted plaintiff conceded this was inaccurate, with only state-law application being similar.

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

No monetary sanctions imposed; warning issued

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/710/Robbins_v._Martin_USA_28_July_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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