What was hallucinated

Fabricated: Case Law | Plaintiff's response (doc. 43 at 23) purports to quote and cite 'Kidd v. Mando Am. Corp., 731 F.3d 1196, 1200 (11th Cir. 2013)', which Defendants and the court identify as a non-existent citation. || Fabricated: Case Law | Plaintiff cites 'Est. of Osorio v. Miami-Dade Cnty., 2023 WL 4003457 (S.D. Fla. June 15, 2023)' (doc. 43 at 24), which Defendants assert and the court notes does not exist. || Fabricated: Case Law | Plaintiff's objection (doc. 49 at 28) cites 'Greer v. DeKalb County, 2009 WL 10101675, at *4 (N.D. Ga. July 13, 2009)', which Defendants identify and the court records as a citation that does not exist or is falsely stated.

Details

The court (adopting the Magistrate Judge's Recommendation) observed that Plaintiff's filings included citations to cases and purported quotations that do not exist; Defendants pointed this out in their filing. The observation was noted but did not result in sanctions; the case was dismissed for failure to state a claim.

Sanction teardown · M.D. Alabama, USA · 2026-03-31

Staley v. City of Elba, et al.

What happened

In M.D. Alabama, 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's response (doc. 43 at 23) purports to quote and cite 'Kidd v. Mando Am. Corp., 731 F.3d 1196, 1200 (11th Cir. 2013)', which Defendants and the court identify as a non-existent citation.
Fabricated (Case Law)

Plaintiff cites 'Est. of Osorio v. Miami-Dade Cnty., 2023 WL 4003457 (S.D. Fla. June 15, 2023)' (doc. 43 at 24), which Defendants assert and the court notes does not exist.
Fabricated (Case Law)

Plaintiff's objection (doc. 49 at 28) cites 'Greer v. DeKalb County, 2009 WL 10101675, at *4 (N.D. Ga. July 13, 2009)', which Defendants identify and the court records as a citation that does not exist or is falsely stated.

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.

Additional detail

The court (adopting the Magistrate Judge's Recommendation) observed that Plaintiff's filings included citations to cases and purported quotations that do not exist; Defendants pointed this out in their filing. The observation was noted but did not result in sanctions; the case was dismissed for failure to state a claim.

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/1911/Staley_USA_31_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).