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Stephen J. Palumbo and Lori A. Palumbo v. Gregory M. Palumbo

Court
Delaware Ch.
Jurisdiction
USA
Decided
2026-08-10
AI tool
Implied
Outcome
Adverse Costs Order
Monetary penalty
1 USD

What was hallucinated

Fabricated: Case Law | Respondent quoted language he attributed to Kuroda v. SPJS Holdings that the court found does not appear in that decision; court described the fabricated quotation as a hallmark of AI usage and used it as evidence of bad faith. || Fabricated: Case Law | Respondent attributed a Rule 12(e) procedural principle to Koninklijke v. Philips that the court found the cited case does not support; the court treated the miscitation as another indicium of fabricated authority.

Sanction teardown · Delaware Ch., USA · 2026-08-10

Stephen J. Palumbo and Lori A. Palumbo v. Gregory M. Palumbo

What happened

In Delaware Ch., 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)
    Respondent quoted language he attributed to Kuroda v. SPJS Holdings that the court found does not appear in that decision; court described the fabricated quotation as a hallmark of AI usage and used it as evidence of bad faith.
  • Fabricated (Case Law)
    Respondent attributed a Rule 12(e) procedural principle to Koninklijke v. Philips that the court found the cited case does not support; the court treated the miscitation as another indicium of fabricated 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

Adverse Costs Order (monetary penalty: 1 USD.)

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/2832/Stephen_J._Palumbo_et_al._v._Gregory_M._Palumbo_USA_10_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2832/Stephen_J._Palumbo_et_al._v._Gregory_M._Palumbo_USA_10_August_2026.pdf

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