What was hallucinated

Fabricated: Case Law | Dodds cited 'United States v. Mateo, 476 F.3d 179, 184 (3d Cir. 2007)' for a proposition and quotation; the reporter pages actually correspond to unrelated cases (In re O'Lexa and Wishkin v. Potter) and do not support the cited proposition. || False Quotes: Case Law | Dodds attributed a quotation to 'United States v. Farrow, 599 F.2d 154 (8th Cir. 1979)'; the citation points to an unrelated opinion and the correct Farrow (580 F.2d 1339) does not support the quoted proposition, so the quotation was misattributed. || Fabricated: Case Law | Dodds cited an apparently fictitious case 'United States v. Matthews, 7 F.3d 1552, 1555 (11th Cir. 1993)' and attributed a quotation to it; the panel found the citation to be entirely fictitious and the quotation fabricated.

Sanction teardown · 10th Cir. CA, USA · 2026-02-11

Thomas Carl Dodds, Jr. v. Carrie Bridges

What happened

In 10th Cir. CA, USA, a filing relied on ChatGPT to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

Dodds cited 'United States v. Mateo, 476 F.3d 179, 184 (3d Cir. 2007)' for a proposition and quotation; the reporter pages actually correspond to unrelated cases (In re O'Lexa and Wishkin v. Potter) and do not support the cited proposition.
False Quotes (Case Law)

Dodds attributed a quotation to 'United States v. Farrow, 599 F.2d 154 (8th Cir. 1979)'; the citation points to an unrelated opinion and the correct Farrow (580 F.2d 1339) does not support the quoted proposition, so the quotation was misattributed.
Fabricated (Case Law)

Dodds cited an apparently fictitious case 'United States v. Matthews, 7 F.3d 1552, 1555 (11th Cir. 1993)' and attributed a quotation to it; the panel found the citation to be entirely fictitious and the quotation fabricated.

Which AI tool

ChatGPT. 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.

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Source: https://www.damiencharlotin.com/documents/1499/THOMAS_CARL_DODDS_JR_Petitioner_-_Appellant_v_CARRIE_BRIDGES_Respondent_-_.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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