Sanction teardown · S.D. New York, USA · 2026-04-30

Sana Hazina Butler v. Fidelity Management & Research Company LLC

What happened

In S.D. New York, 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:

• False Quotes (Case Law)
  Plaintiff cited Maersk, Inc. v. Neewra, Inc. with quoted language the court determined does not appear in that opinion; case exists but does not support the cited proposition.
• Misrepresented (Case Law)
  Plaintiff cited Parisie v. Greer, which exists but the court noted it has nothing to do with removal (misstated relevance).
• Misrepresented (Case Law)
  Plaintiff cited Whitaker v. American Telecasting, which involves removal but does not support the specific proposition about filing a removed complaint as an exhibit; court noted misstatement of holding.
• Fabricated (Case Law)
  Plaintiff cited 'Rong Zhu v. BNP Paribas, 997 F. Supp. 2d 242 (S.D.N.Y. 2014)', which the court found does not exist.
• False Quotes (Case Law)
  Plaintiff attributed quoted language to Granny Goose Foods, but the court found the quoted language does not appear in that opinion; case exists but does not support the cited proposition.
• False Quotes (Case Law)
  Plaintiff cited Azer v. Connell and included quoted language the court found does not appear in the opinion; case exists but the quote is not in it and it is unrelated to the removal issue cited.

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/2078/Butler_v._Fidelity_USA_30_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).