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Thomas Duncan v. Gridhawk et al.

Court
W.D. Texas
Jurisdiction
USA
Decided
2025-12-06
AI tool
Implied
Outcome
Plaintiff's objections struck
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Plaintiff cited 'Valdez v. Joy Techs., 201 F.3d 447 (5th Cir. 2000)'; the court determined this case does not exist and the citation was fabricated. || Fabricated: Case Law | Plaintiff cited 'Cunningham v. Kansas City S. Ry. Co., 2005 WL 2033364, at 3 (S.D. Tex. 2005)'; the court determined this citation does not exist and was fabricated. || False Quotes: Case Law | Plaintiff cited Taylor v. Brighton Corp., 616 F.2d 256, 258 (5th Cir. 1980) and attributed the quotation 'OSHA does not create a private cause of action' to it; the court found the case exists but does not contain that quoted language (false quote).

Sanction teardown · W.D. Texas, USA · 2025-12-06

Thomas Duncan v. Gridhawk et al.

What happened

In W.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:

  • Fabricated (Case Law)
    Plaintiff cited 'Valdez v. Joy Techs., 201 F.3d 447 (5th Cir. 2000)'; the court determined this case does not exist and the citation was fabricated.
  • Fabricated (Case Law)
    Plaintiff cited 'Cunningham v. Kansas City S. Ry. Co., 2005 WL 2033364, at 3 (S.D. Tex. 2005)'; the court determined this citation does not exist and was fabricated.
  • False Quotes (Case Law)
    Plaintiff cited Taylor v. Brighton Corp., 616 F.2d 256, 258 (5th Cir. 1980) and attributed the quotation 'OSHA does not create a private cause of action' to it; the court found the case exists but does not contain that quoted language (false quote).

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

Plaintiff's objections struck

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/1177/Duncan_v_GridHawk_USA_6_December_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1177/Duncan_v_GridHawk_USA_6_December_2025.pdf

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