What was hallucinated

Fabricated: Case Law | Appellant's brief contained allegedly three AI-generated citations to nonexistent cases; doctor alleged fictitious cases produced by GenAI; court recognized at least some citations were fabricated. || Misrepresented: Case Law | Appellant incorrectly cited an unpublished decision that does exist: People in Interest of J.L.S.; citation was misused and violates court's policy on unpublished opinions. || Misrepresented: Case Law | Appellant miscited In re Estate of Ongaro; the case exists but does not articulate the test Hanna attributed to it.

Details

The defendant-appellee alleged that Hanna's brief contained nonexistent case citations generated by a GenAI tool. The court noted alleged fabricated citations and some incorrect citations but declined to impose sanctions against the pro se appellant, affirming the dismissal and denying attorney fees.

Sanction teardown · Colorado CA, USA · 2026-01-08

Saad Hanna v. Kimberly A. Nelson

What happened

In Colorado CA, 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)

Appellant's brief contained allegedly three AI-generated citations to nonexistent cases; doctor alleged fictitious cases produced by GenAI; court recognized at least some citations were fabricated.
Misrepresented (Case Law)

Appellant incorrectly cited an unpublished decision that does exist: People in Interest of J.L.S.; citation was misused and violates court's policy on unpublished opinions.
Misrepresented (Case Law)

Appellant miscited In re Estate of Ongaro; the case exists but does not articulate the test Hanna attributed to it.

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; No adverse costs order

Additional detail

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.

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Source: https://www.damiencharlotin.com/documents/1307/Hanna_v._Nelson_USA_8_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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