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United States of America v. Smith

Court
N.D. Illinois
Jurisdiction
USA
Decided
2026-08-07
AI tool
Implied
Outcome
Order to Show Cause
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Court could not locate or verify the cited case; petitioner relied on this citation to support his §2C1.1 argument. || Fabricated: Case Law | Court could not locate the cited decision that petitioner attributed supporting his sentencing argument. || Fabricated: Case Law | Court could not find the purported case relied on by petitioner in briefing. || Misrepresented: Case Law | Petitioner attributed a holding to Jones that would have required resentencing; Court found the case real but mischaracterized (Jones affirmed the sentence). || Misrepresented: Case Law | Petitioner said Scott supported a cumulative-effect ineffective-assistance argument; Court found Scott did not contain that discussion. || Fabricated: Case Law | Court unable to locate the cited Rivera decision and URL led nowhere; citation unsupported. || Misrepresented: Case Law | Petitioner cited Aviles-Colon as reversing for misrepresentation of loss amount; Court noted Aviles-Colon was a remand in a Brady context and did not support petitioner's asserted point. || Fabricated: Case Law | Court could not locate the cited Johnson decision petitioner relied on for the proposition that prosecutorial exaggeration is improper.

Sanction teardown · N.D. Illinois, USA · 2026-08-07

United States of America v. Smith

What happened

In N.D. Illinois, 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)
    Court could not locate or verify the cited case; petitioner relied on this citation to support his §2C1.1 argument.
  • Fabricated (Case Law)
    Court could not locate the cited decision that petitioner attributed supporting his sentencing argument.
  • Fabricated (Case Law)
    Court could not find the purported case relied on by petitioner in briefing.
  • Misrepresented (Case Law)
    Petitioner attributed a holding to Jones that would have required resentencing; Court found the case real but mischaracterized (Jones affirmed the sentence).
  • Misrepresented (Case Law)
    Petitioner said Scott supported a cumulative-effect ineffective-assistance argument; Court found Scott did not contain that discussion.
  • Fabricated (Case Law)
    Court unable to locate the cited Rivera decision and URL led nowhere; citation unsupported.
  • Misrepresented (Case Law)
    Petitioner cited Aviles-Colon as reversing for misrepresentation of loss amount; Court noted Aviles-Colon was a remand in a Brady context and did not support petitioner's asserted point.
  • Fabricated (Case Law)
    Court could not locate the cited Johnson decision petitioner relied on for the proposition that prosecutorial exaggeration is improper.

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

Order to Show Cause

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/2833/United_States_of_America_v._Smith_USA_7_August_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2833/United_States_of_America_v._Smith_USA_7_August_2026.pdf

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