Sanction teardown · 6th Cir. CA, USA · 2026-04-03
United States v. Farris
What happened
In 6th Cir. CA, USA, a filing relied on Westlaw CoCounsel to help draft legal argument. The court identified the following problems with the citations in that filing:
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Fabricated (Doctrinal Work)AI-generated quoted commentary attributed to U.S.S.G. § 3B1.1 cmt. n.1 did not appear in the cited commentary; the court could not locate similar language in any authority.
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False Quotes (Case Law)Brief attributed a quotation to United States v. Washington ('simply facilitating the offense without exercising decision-making authority is insufficient') that does not appear in that opinion; the court noted Washington in fact upheld the enhancement.
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False Quotes (Case Law)Brief attributed a quotation to United States v. Anthony ('[t]here was no evidence [the defendant] directed or supervised anyone else') that does not appear in the opinion; the court explained Anthony's vacatur was narrow and the defendant had conceded supervisory role.
Which AI tool
Westlaw CoCounsel. 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
Counsel disqualified with no compensation for time served; Briefs locked; Bar Referral; Notice of Opinion
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/1903/USA_v._Farris_USA_3_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).