Sanction teardown · S.D. Texas, USA · 2026-06-30

Susan Elizabeth Duve v. William Charles Forrest, et al.

What happened

In S.D. Texas, 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:

• Misrepresented (Legal Norm)
  GenAI produced unsupported legal propositions and other legal contentions that the plaintiff failed to verify before filing.
• Fabricated (Case Law)
  Notice of removal relied on purported Fifth Circuit authority that does not exist; plaintiff later confirmed no such authority supports the statements.
• False Quotes (Case Law)
  The filing contained inaccurate quotations generated by GenAI that were not independently verified by the plaintiff.

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/2508/Duve_v._Forrest_USA_30_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).