What was hallucinated

Misrepresented: Case Law | Doyle cited Vazquez v. Triad Media Solutions, 2016 WL 155044, at *2 as applying Twombly/Iqbal to affirmative defenses; the court could not locate an opinion supporting that proposition and found the citation mischaracterized. || Misrepresented: Case Law | Doyle cited Herman & MacLean v. Huddleston, 459 U.S. 375, 388 (1983) for an incorrect proposition about punitive damages under the FHA; the court noted Herman & MacLean is a securities case and was misapplied. || Fabricated: Case Law | The motion contained numerous citations that could not be verified or did not support the propositions for which they were cited; the court described these as hallucinatory or fabricated citations and warned the litigant.

Sanction teardown · D. New Jersey, USA · 2026-01-07

United States v. Juliet Payseur and 20-22 McGregor Avenue, LLC

What happened

In D. New Jersey, 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)

Doyle cited Vazquez v. Triad Media Solutions, 2016 WL 155044, at *2 as applying Twombly/Iqbal to affirmative defenses; the court could not locate an opinion supporting that proposition and found the citation mischaracterized.
Misrepresented (Case Law)

Doyle cited Herman & MacLean v. Huddleston, 459 U.S. 375, 388 (1983) for an incorrect proposition about punitive damages under the FHA; the court noted Herman & MacLean is a securities case and was misapplied.
Fabricated (Case Law)

The motion contained numerous citations that could not be verified or did not support the propositions for which they were cited; the court described these as hallucinatory or fabricated citations and warned the litigant.

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

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/1299/USA_v._Payseur_USA_7_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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