What was hallucinated

Misrepresented: Case Law | Counsel cited decisions that granted release for medical conditions that are facially dissimilar to Defendant's conditions; Court found these distinguishable and not supportive. || Misrepresented: Case Law | Counsel cited cases that actually denied compassionate release (presented as supportive authority for medical conditions); the Court flagged these as misleading. || Misrepresented: Case Law | Counsel relied on a district-court decision that was later reversed on appeal but cited it as supportive; the Court noted the reversal undermines its use as authority. || Misrepresented: Case Law | Counsel cited cases that granted compassionate release, but did so based on non-medical family or sentencing-change reasons—not the medical grounds counsel relied upon; Court found those citations inapposite.

Sanction teardown · W.D. Missouri, USA · 2026-02-10

United States v. Clint Travis Rodgers

What happened

In W.D. Missouri, 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:

Misrepresented (Case Law)

Counsel cited decisions that granted release for medical conditions that are facially dissimilar to Defendant's conditions; Court found these distinguishable and not supportive.
Misrepresented (Case Law)

Counsel cited cases that actually denied compassionate release (presented as supportive authority for medical conditions); the Court flagged these as misleading.
Misrepresented (Case Law)

Counsel relied on a district-court decision that was later reversed on appeal but cited it as supportive; the Court noted the reversal undermines its use as authority.
Misrepresented (Case Law)

Counsel cited cases that granted compassionate release, but did so based on non-medical family or sentencing-change reasons—not the medical grounds counsel relied upon; Court found those citations inapposite.

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

Admonishment

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/1501/UNITED_STATES_OF_AMERICA_Plaintiff_v_2_CLINT_TRAVIS_RODGERS_Defendant.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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