What was hallucinated

Misrepresented: Case Law | Cited Boudreaux v. Boudreaux to support tenant-rights and non-waiver-by-continued-occupancy propositions, but the cited case concerns whether a principal was a statutory employer; the opinion's holding was misrepresented. || Fabricated: Case Law | Cited 'Miller v. Housing Authority of New Orleans' for constructive eviction and rent-withholding; court could not locate the case and reporter/volume pointed to unrelated Rosen decision; court concluded the citation was fabricated/AI-generated.

Details

Counsel admitted he did not verify citations. The court imposed a $1,000 sanction payable personally by counsel, ordered 1 hour CLE on generative AI, and referred him to the Disciplinary Committee.

Sanction teardown · E.D. Louisiana, USA · 2025-10-02

Robenson Lafontant v. Coolidge-CLK St. Germaine

What happened

In E.D. Louisiana, 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:

Misrepresented (Case Law)

Cited Boudreaux v. Boudreaux to support tenant-rights and non-waiver-by-continued-occupancy propositions, but the cited case concerns whether a principal was a statutory employer; the opinion's holding was misrepresented.
Fabricated (Case Law)

Cited 'Miller v. Housing Authority of New Orleans' for constructive eviction and rent-withholding; court could not locate the case and reporter/volume pointed to unrelated Rosen decision; court concluded the citation was fabricated/AI-generated.

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

Monetary Sanction; 1h of CLE; Referral (monetary penalty: 1000 USD.)

Additional detail

Counsel admitted he did not verify citations. The court imposed a $1,000 sanction payable personally by counsel, ordered 1 hour CLE on generative AI, and referred him to the Disciplinary Committee.

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/918/Lafontant_v._Coolidge_CLK_USA_3_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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