What was hallucinated

Fabricated: Case Law | Plaintiff cited a non-existent case the Court could not locate. || Fabricated: Case Law | Plaintiff cited a non-existent case the Court could not locate. || Fabricated: Case Law | Plaintiff cited a non-existent case the Court could not locate. || Fabricated: Case Law | Plaintiff cited a non-existent case the Court could not locate. || Misrepresented: Case Law | Plaintiff relied on Goodwin v. District of Columbia as establishing a pattern relevant to his healthcare-benefits claims; the Court noted Goodwin involved protesters’ First and Fourth Amendment Monell claims and bore little resemblance.

Details

AI UsePlaintiff’s proposed second amended complaint included multiple fictitious legal authorities, phrased in language suggesting generative AI use (e.g., “Here are some relevant legal precedents...”). The court stated it “bears some of the hallmarks of an AI response” and noted that the citations appeared to have been “invented by artificial intelligence (‘AI’).”Hallucination DetailsThe court could not locate the following cited cases:Ford v. District of Columbia, 70 F.3d 231 (D.C. Cir. 1995)Davis v. District of Columbia, 817 A.2d 1234 (D.C. 2003)Ward v. District of Columbia, 818 A.2d 27 (D.C. 2003)Reese v. District of Columbia, 37 A.3d 232 (D.C. 2012)These were used to allege a pattern of constitutional violations by the District but were found to be fabricated.Ruling/SanctionThe court denied Plaintiff’s motion to file a second amended complaint and dismissed the federal claims with prejudice. No formal Rule 11 sanctions were imposed, but the court emphasized the importance of verifying legal citations, citing Mata v. Avianca as precedent for how courts have responded to similar AI-related misuse.Key Judicial ReasoningThe Court noted that while AI may be a helpful tool for pro se litigants, its use does not relieve them of the obligation to verify that every citation is real. The submission of fictitious legal authorities, even if inadvertent, is improper and may warrant sanctions. Here, the repeated failure to plead a viable claim after multiple amendments led to dismissal with prejudice.

Sanction teardown · D. DC, USA · 2024-12-03

Rubio v. District of Columbia DHS

What happened

In D. DC, 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 case the Court could not locate.
Fabricated (Case Law)

Plaintiff cited a non-existent case the Court could not locate.
Fabricated (Case Law)

Plaintiff cited a non-existent case the Court could not locate.
Fabricated (Case Law)

Plaintiff cited a non-existent case the Court could not locate.
Misrepresented (Case Law)

Plaintiff relied on Goodwin v. District of Columbia as establishing a pattern relevant to his healthcare-benefits claims; the Court noted Goodwin involved protesters’ First and Fourth Amendment Monell claims and bore little resemblance.

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

Complaint dismissed with prejudice; no Rule 11 sanctions imposed, but clear judicial warning on AI misuse and citation verification duties

Additional detail

AI UsePlaintiff’s proposed second amended complaint included multiple fictitious legal authorities, phrased in language suggesting generative AI use (e.g., “Here are some relevant legal precedents...”). The court stated it “bears some of the hallmarks of an AI response” and noted that the citations appeared to have been “invented by artificial intelligence (‘AI’).”Hallucination DetailsThe court could not locate the following cited cases:Ford v. District of Columbia, 70 F.3d 231 (D.C. Cir. 1995)Davis v. District of Columbia, 817 A.2d 1234 (D.C. 2003)Ward v. District of Columbia, 818 A.2d 27 (D.C. 2003)Reese v. District of Columbia, 37 A.3d 232 (D.C. 2012)These were used to allege a pattern of constitutional violations by the District but were found to be fabricated.Ruling/SanctionThe court denied Plaintiff’s motion to file a second amended complaint and dismissed the federal claims with prejudice. No formal Rule 11 sanctions were imposed, but the court emphasized the importance of verifying legal citations, citing Mata v. Avianca as precedent for how courts have responded to similar AI-related misuse.Key Judicial ReasoningThe Court noted that while AI may be a helpful tool for pro se litigants, its use does not relieve them of the obligation to verify that every citation is real. The submission of fictitious legal authorities, even if inadvertent, is improper and may warrant sanctions. Here, the repeated failure to plead a viable claim after multiple amendments led to dismissal with prejudice.

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/308/Rubio_v._DC_DHS_US_DC_District_Court_December_3_2024.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).