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Smith v. Clarence Smith et al.

Court
N.D. New York
Jurisdiction
USA
Decided
2025-12-22
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited 'In re D.C. Judicial Conflicts of Interest, 540 F.2d 711 (D.C. Cir. 1976),' which the court found does not exist and is a fabricated citation. || Fabricated: Case Law | Plaintiff cited 'In re B.W., 352 F.3d 29 (2d Cir. 2003),' which the court determined does not exist and appears to be AI-generated. || Fabricated: Case Law | Plaintiff cited 'Wilkinson v. United States, 13 F.3d 855 (2d Cir. 1994),' which the court found to be nonexistent and unrelated to any real opinion at that reporter citation. || Misrepresented: Case Law | Plaintiff mis-cited Keir v. Schoeberl with an incorrect Westlaw citation ('2025 WL 1123456'); the court identified the correct citation as 2025 WL 437953, noting continued mis-citation of authority. || Misrepresented: Case Law | Plaintiff mis-cited Bennett v. Mnuchin with an incorrect Westlaw citation ('2020 WL 3214565'); the court noted the correct citation is 2020 WL 4432662, indicating miscitation rather than a substantive supporting authority.

Sanction teardown · N.D. New York, USA · 2025-12-22

Smith v. Clarence Smith et al.

What happened

In N.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:

  • Fabricated (Case Law)
    Plaintiff cited 'In re D.C. Judicial Conflicts of Interest, 540 F.2d 711 (D.C. Cir. 1976),' which the court found does not exist and is a fabricated citation.
  • Fabricated (Case Law)
    Plaintiff cited 'In re B.W., 352 F.3d 29 (2d Cir. 2003),' which the court determined does not exist and appears to be AI-generated.
  • Fabricated (Case Law)
    Plaintiff cited 'Wilkinson v. United States, 13 F.3d 855 (2d Cir. 1994),' which the court found to be nonexistent and unrelated to any real opinion at that reporter citation.
  • Misrepresented (Case Law)
    Plaintiff mis-cited Keir v. Schoeberl with an incorrect Westlaw citation ('2025 WL 1123456'); the court identified the correct citation as 2025 WL 437953, noting continued mis-citation of authority.
  • Misrepresented (Case Law)
    Plaintiff mis-cited Bennett v. Mnuchin with an incorrect Westlaw citation ('2020 WL 3214565'); the court noted the correct citation is 2020 WL 4432662, indicating miscitation rather than a substantive supporting 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

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/1228/Smith_v._Smith_USA_22_December_2022.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1228/Smith_v._Smith_USA_22_December_2022.pdf

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