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Serafin v. United States Department of State, et al.

Court
E.D. Missouri
Jurisdiction
USA
Decided
2025-10-16
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiffs cited 'Escobar v. INS, 935 F.2d 955 (8th Cir. 1991)'; the Court found the citation non-existent/miscited (935 F.2d 955 corresponds to a different case, United States v. Lee). || Fabricated: Case Law | Defendants noted the cited case 'Lazo v. Blinken, No. 7:21-cv-00313, 2022 WL 1316223 (S.D. Tex. May 3, 2022)' does not exist. || Fabricated: Case Law | Defendants noted the cited case 'Flores-Torres v. DHS, 548 F.3d 1, 6 (1st Cir. 2008)' does not exist. || Misrepresented: Case Law | Plaintiffs relied on 'Flores-Villar v. United States, 564 U.S. 210 (2011)' as supporting a derivative-parental-citizenship proposition; the Court stated the citation is an unexplained affirmance and does not support Plaintiffs' asserted rule. || Misrepresented: Case Law | Plaintiffs invoked 'Hughes v. Ashcroft, 255 F.3d 752 (9th Cir. 2001)' to support a derivative-children theory; the Court explained Hughes did not concern derivative citizenship and was inapposite.

Sanction teardown · E.D. Missouri, USA · 2025-10-16

Serafin v. United States Department of State, et al.

What happened

In E.D. Missouri, 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)
    Plaintiffs cited 'Escobar v. INS, 935 F.2d 955 (8th Cir. 1991)'; the Court found the citation non-existent/miscited (935 F.2d 955 corresponds to a different case, United States v. Lee).
  • Fabricated (Case Law)
    Defendants noted the cited case 'Lazo v. Blinken, No. 7:21-cv-00313, 2022 WL 1316223 (S.D. Tex. May 3, 2022)' does not exist.
  • Fabricated (Case Law)
    Defendants noted the cited case 'Flores-Torres v. DHS, 548 F.3d 1, 6 (1st Cir. 2008)' does not exist.
  • Misrepresented (Case Law)
    Plaintiffs relied on 'Flores-Villar v. United States, 564 U.S. 210 (2011)' as supporting a derivative-parental-citizenship proposition; the Court stated the citation is an unexplained affirmance and does not support Plaintiffs' asserted rule.
  • Misrepresented (Case Law)
    Plaintiffs invoked 'Hughes v. Ashcroft, 255 F.3d 752 (9th Cir. 2001)' to support a derivative-children theory; the Court explained Hughes did not concern derivative citizenship and was inapposite.

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/878/Serafin_v._Rubio_USA_16_October_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/878/Serafin_v._Rubio_USA_16_October_2025.pdf

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