What was hallucinated

False Quotes: Case Law | Counsel attributed the quoted language "whether a worker is a 'borrowed servant' is generally a question of fact to be decided by the jury" to Gorton v. Rance; the court found no such quotation or discussion in the opinion. || False Quotes: Case Law | Counsel claimed Starcher v. Byrne held borrowed-servant disputes are factual issues for the jury and cannot be decided on summary judgment; the court found Starcher does not contain that holding or the quoted language. || Misrepresented: Case Law | Counsel miscited James v. Dedeaux as 242 So. 3d 905 and represented a rule (that facts must be undisputed) that the court says is not the majority holding; the correct citation is 217 So. 3d 785 and the brief appears to rely on a dissent. || Misrepresented: Case Law | Counsel asserted Dawson v. Burgs established specific "elements" (e.g., 'first and most critical element is the existence of a contract of hire') and limits on implied contracts that the court found are not present in Dawson. || Misrepresented: Case Law | Counsel attributed language about 'vicarious liability' and other holdings to Northern Electric Co. v. Phillips that the court could not find in that opinion.

Sanction teardown · CC Copiah County Mississippi, USA · 2026-07-06

Swinney v. JHOC, Inc.

What happened

In CC Copiah County Mississippi, 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:

False Quotes (Case Law)

Counsel attributed the quoted language "whether a worker is a 'borrowed servant' is generally a question of fact to be decided by the jury" to Gorton v. Rance; the court found no such quotation or discussion in the opinion.
False Quotes (Case Law)

Counsel claimed Starcher v. Byrne held borrowed-servant disputes are factual issues for the jury and cannot be decided on summary judgment; the court found Starcher does not contain that holding or the quoted language.
Misrepresented (Case Law)

Counsel miscited James v. Dedeaux as 242 So. 3d 905 and represented a rule (that facts must be undisputed) that the court says is not the majority holding; the correct citation is 217 So. 3d 785 and the brief appears to rely on a dissent.
Misrepresented (Case Law)

Counsel asserted Dawson v. Burgs established specific "elements" (e.g., 'first and most critical element is the existence of a contract of hire') and limits on implied contracts that the court found are not present in Dawson.
Misrepresented (Case Law)

Counsel attributed language about 'vicarious liability' and other holdings to Northern Electric Co. v. Phillips that the court could not find in that opinion.

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.

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/2707/Swinney_v._Jhoc_USA_6_jUly_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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