What was hallucinated

Fabricated: Case Law | Plaintiffs repeatedly cited a non-existent opinion 'Peal v. Commonwealth' as supporting a foundational probable-cause requirement; court found the case does not exist. || Fabricated: Case Law | Plaintiffs cited 'Ford v. City of Alexandria, 37 Va. App. 819 (2002)', which the court determined is not an existing opinion cited in that form. || Fabricated: Case Law | Plaintiffs relied on 'Lafayette v. Commonwealth, 30 Va. App. 454 (1999)'; court determined the cited authority does not exist. || Misrepresented: Legal Norm | Plaintiffs misquoted Virginia Code § 19.2-72 to assert a categorical requirement of a sworn, written probable-cause affidavit for misdemeanor warrants; court corrected that the statute does not impose that written-affidavit requirement when the complainant is a law-enforcement officer. || Misrepresented: Case Law | Plaintiffs quoted McCary v. Commonwealth for the proposition that 'Probable cause must appear within the four corners of the written affidavit or recorded testimony presented to the magistrate,' but the court found McCary does not contain that language and was misused. || Misrepresented: Case Law | Plaintiffs cited 'Anderson v. Commonwealth, 38 Va. App. 321 (2002), aff'd, 279 Va. 85 (2010)' for a legal proposition about in-camera review; court found the citation/misattribution was incorrect and the cited authority did not support the proposition. || Fabricated: Case Law | Complaint cited 'Walker v. Bowen, 372 F. Supp. 2d 541 (W.D. Va. 2005)' as precedent; court found no such authority.

Sanction teardown · W.D. Virginia, USA · 2026-05-20

Sherwood v. County of Botetourt, Virginia, et al.

What happened

In W.D. Virginia, 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 repeatedly cited a non-existent opinion 'Peal v. Commonwealth' as supporting a foundational probable-cause requirement; court found the case does not exist.
Fabricated (Case Law)

Plaintiffs cited 'Ford v. City of Alexandria, 37 Va. App. 819 (2002)', which the court determined is not an existing opinion cited in that form.
Fabricated (Case Law)

Plaintiffs relied on 'Lafayette v. Commonwealth, 30 Va. App. 454 (1999)'; court determined the cited authority does not exist.
Misrepresented (Legal Norm)

Plaintiffs misquoted Virginia Code § 19.2-72 to assert a categorical requirement of a sworn, written probable-cause affidavit for misdemeanor warrants; court corrected that the statute does not impose that written-affidavit requirement when the complainant is a law-enforcement officer.
Misrepresented (Case Law)

Plaintiffs quoted McCary v. Commonwealth for the proposition that 'Probable cause must appear within the four corners of the written affidavit or recorded testimony presented to the magistrate,' but the court found McCary does not contain that language and was misused.
Misrepresented (Case Law)

Plaintiffs cited 'Anderson v. Commonwealth, 38 Va. App. 321 (2002), aff'd, 279 Va. 85 (2010)' for a legal proposition about in-camera review; court found the citation/misattribution was incorrect and the cited authority did not support the proposition.
Fabricated (Case Law)

Complaint cited 'Walker v. Bowen, 372 F. Supp. 2d 541 (W.D. Va. 2005)' as precedent; court found no such authority.

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

Not specified in source record.

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/2161/Sherwood_v_Botetourt.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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