Sanction teardown · CA Indiana, USA · 2025-09-24
T.M. v. M.M.
What happened
In CA Indiana, 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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False Quotes (Case Law)Appellant cited a quotation supposedly supporting judicial estoppel that the court found is not present in the cited case.
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Fabricated (Case Law)Appellant cited a non-existent case 'Reynolds v. State' as authority; the court found the case does not exist.
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Fabricated (Case Law)Appellant cited 'Robison v. Orthopedic & Sports Medicine Center' with a reporter citation that the court states does not exist.
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Fabricated (Case Law)Appellant relied on purported authority 'Bill v. Bill' which the court found to be non-existent.
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Fabricated (Case Law)Appellant cited 'Wann v. Wann' as controlling authority; the court states the cited case does not exist.
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Fabricated (Case Law)Appellant cited 'A.H.L. v. C.Y.L.' which the court determined is not a real reported decision.
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Misrepresented (Legal Norm)Appellant mischaracterized the content/purpose of a statute, citing Ind. Code § 33-25-1-2 as establishing appellate jurisdiction when it establishes court districts.
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Misrepresented (Exhibits & Submissions)Appellant cited transcript page references that the court found do not support the assertions (various transcript page citations mis-cited).
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
Additional detail
The Court preserved the invalid citations in the opinion as they are part of the record, admonished that fabricated or incorrect citations frustrate review and may lead to reprimand or sanction.
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/841/TM_Appellant-Respondent_v_MM_Appellee-Petitioner.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).