Sanction teardown · W.D. Washington, USA · 2025-10-14
Robert Allen Reed et al. v. Community Health Care et al.
What happened
In W.D. Washington, 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)Plaintiffs cited “Flores v. United States, 189 F.3d 477, 481 (9th Cir. 1999)”; the Court found this decision does not exist and identified it as part of a pattern of fictitious citations.
-
Fabricated (Case Law)Plaintiffs cited “Abbey v. United States, 953 F.2d 639, 642 (9th Cir. 1991)”; the Court determined this decision does not exist and characterized it as fictitious.
-
Fabricated (Case Law)Plaintiffs cited “Urrutia, 44 F.3d at 1265” as authority; the Court identified this citation among decisions that do not exist and treated it as fabricated.
-
Fabricated (Case Law)Plaintiffs relied on “State v. Kaiser, 198 Wn. App. 142 (2017)” to support a WCPA theory; the Court found no such decision exists and labeled the citation fictitious.
-
Fabricated (Case Law)Plaintiffs cited “Right v. Breen, 128 Wn. App. 104 (2005)” for defamation law; the Court concluded this authority does not exist and flagged it as fabricated.
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
Warning
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/874/Reed_v._Community_USA_14_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).