Sanction teardown · D. Minnesota, USA · 2026-02-04
Sophia Madigan v. Graco Inc.
What happened
In D. Minnesota, 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:
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Fabricated (Case Law)Plaintiff cited "LaPoint v. Family Orthodontics, P.A., 2020 WL 6118773 (D. Minn. Oct. 16, 2020)" for a point about HR treating a doctor's note as optional; the court found the decision at that citation is an unrelated SEC case and the Minnesota Supreme Court LaPoint decision exists but does not support plaintiff's contention.
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Fabricated (Case Law)Plaintiff cited "Hernandez v. Best Buy Co., 2012 WL 1970771 (D. Minn. May 31, 2012)" to support an MPLA argument; the court found no such decision at that citation (the citation corresponds to an unrelated Sixth Circuit insurance case). Court noted the citation was incorrect after defendant pointed it out.
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/1472/Sophia_Madigan_v_Graco_Inc_USA_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).