Sanction teardown · Minnesotta DC, USA · 2026-01-13
Viken v. Schuelke
What happened
In Minnesotta DC, USA, a filing relied on Lexis Assist to help draft legal argument. The court identified the following problems with the citations in that filing:
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False Quotes (Case Law)Memorandum attributes the quotation 'failure to properly serve required parties invalidates the termination of the contract for deed and, consequently, the vendor's standing to bring title-based lawsuits.' to Enga v. Felland, but the quote does not appear in Enga.
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False Quotes (Case Law)Memorandum attributes the phrase 'service requirements are "prerequisite to pursuing an action"' to Enga v. Felland, but that phrasing does not appear in the case as cited.
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False Quotes (Case Law)Memorandum attributes the quotation that vendors who failed to serve notice 'did not comply with statutory requirements for cancellation' to Ahlstrand v. McPherson, but the court did not locate that quotation in the cited opinion.
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Misrepresented (Case Law)Memorandum repeatedly asserts the broad proposition that 'vendors under a contract for deed generally lack standing to bring title-based lawsuits before properly terminating the contract for deed' without any controlling or persuasive authority; cited cases do not support that proposition.
Which AI tool
Lexis Assist. 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.
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Source: https://www.damiencharlotin.com/documents/2337/10_-_Viken_v_Schuelke.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).