Sanction teardown · S.D. Indiana, USA · 2026-02-12

Virgil v. Experian Information Solutions, et al.

What happened

In S.D. Indiana, 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)
  Counsel cited Myers v. Passport Health, 2013 WL 5819270 (S.D. Ind. Oct. 29, 2013); court found this citation does not exist.
• Fabricated (Case Law)
  Counsel cited Schuh v. American Express Bank, FSB, 2019 WL 132741 (N.D. Ind. Jan. 8, 2019); court found the citation does not exist.
• Fabricated (Case Law)
  Same non-existent Myers citation also appeared in a separate filing (Docket 240); court found it does not exist.
• Fabricated (Case Law)
  Counsel cited Merriman v. Equifax Info. Servs., LLC, 2021 WL 5937732 (D. Kan. Dec. 16, 2021); court found this citation does not exist.
• Fabricated (Case Law)
  Counsel cited Treece v. Perrillo, No. 1:17-cv-00406, 2018 WL 3815004 (S.D. Ind. Aug. 10, 2018); court found the opinion does not exist.
• Fabricated (Case Law)
  Counsel cited Armstrong v. Kroger Co., 621 F.2d 934 (8th Cir. 1980); court found this citation to be non-existent as cited.
• Fabricated (Case Law)
  Counsel cited Hinkle v. CBE Grp., 827 F.3d 129 (5th Cir. 2016); court determined the cited opinion does not exist.
• Fabricated (Case Law)
  Counsel cited Wigington v. Hill-Soberg Co., 396 F.2d 228 (5th Cir. 1968); court found the citation non-existent.
• Fabricated (Case Law)
  Counsel cited Jenkins v. Equifax Info. Servs., LLC, 736 F. Supp. 2d 962 (E.D. Va. 2010); court found the citation does not exist.
• Fabricated (Case Law)
  Counsel cited Rodriguez v. Pasquarella, 2019 WL 2411480 (N.D. Ill. June 7, 2019); court found this citation non-existent.
• Misrepresented (Case Law)
  Counsel cited Harris v. Mexican Specialty Foods, Inc., 564 F.3d 1301 (11th Cir. 2009); court found the case exists but was misrepresented for the proposition cited.
• Misrepresented (Case Law)
  Counsel cited Wright v. Experian Info. Sols., Inc., 805 F.3d 1232 (10th Cir. 2015); court found the citation was misrepresented and did not support the asserted point.
• Misrepresented (Case Law)
  Counsel cited In re TJX Cos. Retail Sec. Breach Litig., 524 F. Supp. 2d 83 (D. Mass. 2007); court concluded the citation was misrepresented as to the issue relied upon.
• Misrepresented (Case Law)
  Counsel cited King v. Gen. Info. Servs., Inc., 903 F. Supp. 2d 303 (E.D. Pa. 2012); court found the citation was misrepresented for the proposition cited.
• Fabricated (Case Law)
  Counsel cited Myers v. Asset Acceptance, LLC, 750 F.3d 910, 915-17 (11th Cir. 2014); court found this specific citation does not exist.

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

Magistrate recommended Monetary Sanction and Bar Referral (monetary penalty: 1 .)

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/1498/SETH_CAMERON_VIRGIL_Plaintiff_v_EXPERIAN_INFORMATION_SOLUTIONS_INC_et_al_D.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).