What was hallucinated

Fabricated: Case Law | Plaintiff admitted that multiple citations in his Reply were fabricated; court accepted notice of clarification. || False Quotes: Case Law | Court asked for clarification of quoted language Plaintiff attributed to the Fifth Circuit in Will-Drill Resources, suggesting the quotation/source could not be verified. || Misrepresented: Case Law | Plaintiff cited a purported holding from Hays v. HCA Holdings, Inc.; court requested clarification on the purported holding (source/accuracy unclear). || Fabricated: Case Law | Plaintiff cited Turner v. Murphy Oil USA, Inc., 2006 WL 1984362 (E.D. La. July 13, 2006); the court was unable to locate any case matching that Westlaw citation or an order dated July 13, 2006 in the district record.

Sanction teardown · E.D. Lousiana, USA · 2026-05-11

Taiujuan Burches v. Equifax Information Services, LLC, et al.

What happened

In E.D. Lousiana, 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 admitted that multiple citations in his Reply were fabricated; court accepted notice of clarification.
False Quotes (Case Law)

Court asked for clarification of quoted language Plaintiff attributed to the Fifth Circuit in Will-Drill Resources, suggesting the quotation/source could not be verified.
Misrepresented (Case Law)

Plaintiff cited a purported holding from Hays v. HCA Holdings, Inc.; court requested clarification on the purported holding (source/accuracy unclear).
Fabricated (Case Law)

Plaintiff cited Turner v. Murphy Oil USA, Inc., 2006 WL 1984362 (E.D. La. July 13, 2006); the court was unable to locate any case matching that Westlaw citation or an order dated July 13, 2006 in the district record.

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

Monetary Sanction (monetary penalty: 500 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/2146/Burches_v._Equifax_USA_11_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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