What was hallucinated

False Quotes: Case Law | Plaintiff attributed the phrase “would offer a possible temptation to the average man as a judge to forget the burden of proof” to Withrow v. Larkin, but the court found that language does not appear in Withrow. || Fabricated: Other | Court noted risk that AI research/drafting tools can hallucinate or fabricate legal authority, possibly explaining some of the plaintiff's inaccurate citations. || Misrepresented: Case Law | Plaintiff cited Bittinger v. Tecumseh Products Co. for the proposition that voluntary engagement with a motion waives procedural objections, but the court found Bittinger (an ERISA/res judicata/privity case) does not support that waiver proposition.

Sanction teardown · D. Nevada, USA · 2026-05-05

Seeto v. Kendall

What happened

In D. Nevada, 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 attributed the phrase “would offer a possible temptation to the average man as a judge to forget the burden of proof” to Withrow v. Larkin, but the court found that language does not appear in Withrow.
Fabricated (Other)

Court noted risk that AI research/drafting tools can hallucinate or fabricate legal authority, possibly explaining some of the plaintiff's inaccurate citations.
Misrepresented (Case Law)

Plaintiff cited Bittinger v. Tecumseh Products Co. for the proposition that voluntary engagement with a motion waives procedural objections, but the court found Bittinger (an ERISA/res judicata/privity case) does not support that waiver proposition.

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.

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Source: https://www.damiencharlotin.com/documents/2109/Seeto_v._Kendall_USA_5_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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