Sanction teardown · N.D. Ohio, USA · 2025-10-30
Safe Choice, LLC v. City of Cleveland
What happened
In N.D. Ohio, USA, a filing relied on Amicus (Casemine) to help draft legal argument. The court identified the following problems with the citations in that filing:
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Misrepresented (Case Law)Attorney attributed the phrase 'fresh injury' to Kuhnle; court found the Sixth Circuit never used that phrase and deemed the citation misrepresented.
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Fabricated (Case Law)Court could not locate this opinion; counsel conceded she could not find or certify its existence.
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Fabricated (Case Law)Court could not locate this opinion; counsel conceded she could not find or certify its existence.
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Misrepresented (Case Law)Attorney claimed Jackson supports a 'custom of tolerance' Monell theory; court found Jackson addressed official policy and failure-to-train theories, not the theory advanced.
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Misrepresented (Case Law)Attorney represented Burgess as finding failure to respond could amount to ratification; court noted Burgess held after-the-fact approval insufficient to establish Monell claim.
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Misrepresented (Case Law)Attorney cited Huffman for a proposition about conspiracy; court observed the word 'conspiracy' does not appear in Huffman and the proposition was inaccurate.
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Misrepresented (Case Law)Attorney claimed Doe v. Claiborne County supports that punitive damages cannot be dismissed at pleading stage; court found 'punitive' does not appear in the opinion.
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Misrepresented (Case Law)Attorney cited Conley and Doe v. Columbia Univ. for a broad proposition about damages demands at pleading stage; court found those authorities did not support the asserted proposition.
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Fabricated (Case Law)Court could not locate this opinion; counsel conceded she could not find or certify its existence.
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Fabricated (Case Law)Court could not locate this opinion; counsel conceded she could not find or certify its existence.
Which AI tool
Amicus (Casemine). 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; Referral to the Bar; Order to serve decision on clinet; (monetary penalty: 7500 USD.)
Additional detail
Order to show cause is here.
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/961/Safe_Choice_v._City_of_Cleveland_USA_30_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).