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United States of America v. Lorenzio Reshaud Simmons

Court
E.D. North Carolina
Jurisdiction
USA
Decided
2025-10-03
AI tool
Unidentified
Outcome
Warning; Allowed to file corrected brief
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Memorandum cited 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012)' — court found no such Fourth Circuit case (citation appears fabricated). || Fabricated: Case Law | Memorandum cited 'United States v. Angel, 102 F.3d 1066 (4th Cir. 1996)' for a quoted rule; court found no such Fourth Circuit decision or matching quoted language. || Misrepresented: Case Law | Memorandum cited 'United States v. Brehm, 442 F.3d 1291, 1293 (4th Cir. 2006)' and attributed the quote 'any uncertainty should be resolved in the defendant's favor.' The court noted the cited Brehm reference is to a different circuit and does not contain that quoted language. || Misrepresented: Case Law | Memorandum cited 'United States v. Nealy, 232 F.3d 825, 829 (4th Cir. 2000)' for language about burdens the government cannot meet; court found the citation is to a different circuit and does not contain the asserted language. || False Quotes: Case Law | Memorandum cited 'United States v. Edwards, 188 F.3d 230, 232 (4th Cir. 1999)' and quoted that packaging weight should not be included; court found Edwards does not contain that quoted language (false quotation). || Misrepresented: Case Law | Memorandum cited 'United States v. Harrision, 918 F.2d 469, 473 (4th Cir. 1990)' for a statement that laboratory testing is more precise; court noted the correct case is in a different circuit (Fifth) and does not contain that quoted text.

Sanction teardown · E.D. North Carolina, USA · 2025-10-03

United States of America v. Lorenzio Reshaud Simmons

What happened

In E.D. North Carolina, 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)
    Memorandum cited 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012)' — court found no such Fourth Circuit case (citation appears fabricated).
  • Fabricated (Case Law)
    Memorandum cited 'United States v. Angel, 102 F.3d 1066 (4th Cir. 1996)' for a quoted rule; court found no such Fourth Circuit decision or matching quoted language.
  • Misrepresented (Case Law)
    Memorandum cited 'United States v. Brehm, 442 F.3d 1291, 1293 (4th Cir. 2006)' and attributed the quote 'any uncertainty should be resolved in the defendant's favor.' The court noted the cited Brehm reference is to a different circuit and does not contain that quoted language.
  • Misrepresented (Case Law)
    Memorandum cited 'United States v. Nealy, 232 F.3d 825, 829 (4th Cir. 2000)' for language about burdens the government cannot meet; court found the citation is to a different circuit and does not contain the asserted language.
  • False Quotes (Case Law)
    Memorandum cited 'United States v. Edwards, 188 F.3d 230, 232 (4th Cir. 1999)' and quoted that packaging weight should not be included; court found Edwards does not contain that quoted language (false quotation).
  • Misrepresented (Case Law)
    Memorandum cited 'United States v. Harrision, 918 F.2d 469, 473 (4th Cir. 1990)' for a statement that laboratory testing is more precise; court noted the correct case is in a different circuit (Fifth) and does not contain that quoted text.

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; Allowed to file corrected brief

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/1658/USA_v._Simmons_USA_10_March_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1658/USA_v._Simmons_USA_10_March_2026.pdf

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