What was hallucinated

Fabricated: Case Law | Brief cited 'Berg v. Knox Cnty., 2024 WL 2012345, at *4 (6th Cir. Mar. 12, 2024)'; the court could not locate any such Sixth Circuit opinion and the WL citation produced no opinion. || Fabricated: Legal Norm | Brief cited a non-existent Tennessee statute section 'T.C.A. § 29-12-119'; the court could not find that section in the Tennessee Code Annotated. || False Quotes: Case Law | Brief repeatedly quoted '"[T]he mere fact that a plaintiff did not prevail does not mean that the claim was frivolous."' and attributed it to Adcock-Ladd v. Secretary of the Treasury, but that language does not appear in Adcock-Ladd. || False Quotes: Case Law | Brief attributed several quoted propositions to Fox v. Vice that do not appear in that opinion; the court found the quoted language absent from Fox. || Misrepresented: Case Law | Brief cited 'Jones v. Hamilton Cnty., 29 F.4th 647, 655 (6th Cir. 2022)' for a Sixth Circuit proposition, but the reporter pages cited corresponded to unrelated Tenth Circuit opinions; the Sixth Circuit Jones exists only as an unpublished opinion and was misrepresented. || Misrepresented: Exhibits & Submissions | Brief cited Complaint paragraph (R.31, ¶32) as stating that 'citizens were forced to park on highways and streets,' but the cited paragraph did not contain that statement. || Misrepresented: Case Law | Brief claimed Lindke v. Freed overruled the district court on legislative immunity and that Lindke addressed legislative immunity; the court noted Lindke concerned social-media blocking and was mischaracterized.

Sanction teardown · 6th Cir. CA, USA · 2026-03-13

Whiting v. City of Athens, Tenn.

What happened

In 6th Cir. CA, 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)

Brief cited 'Berg v. Knox Cnty., 2024 WL 2012345, at *4 (6th Cir. Mar. 12, 2024)'; the court could not locate any such Sixth Circuit opinion and the WL citation produced no opinion.
Fabricated (Legal Norm)

Brief cited a non-existent Tennessee statute section 'T.C.A. § 29-12-119'; the court could not find that section in the Tennessee Code Annotated.
False Quotes (Case Law)

Brief repeatedly quoted '"[T]he mere fact that a plaintiff did not prevail does not mean that the claim was frivolous."' and attributed it to Adcock-Ladd v. Secretary of the Treasury, but that language does not appear in Adcock-Ladd.
False Quotes (Case Law)

Brief attributed several quoted propositions to Fox v. Vice that do not appear in that opinion; the court found the quoted language absent from Fox.
Misrepresented (Case Law)

Brief cited 'Jones v. Hamilton Cnty., 29 F.4th 647, 655 (6th Cir. 2022)' for a Sixth Circuit proposition, but the reporter pages cited corresponded to unrelated Tenth Circuit opinions; the Sixth Circuit Jones exists only as an unpublished opinion and was misrepresented.
Misrepresented (Exhibits & Submissions)

Brief cited Complaint paragraph (R.31, ¶32) as stating that 'citizens were forced to park on highways and streets,' but the cited paragraph did not contain that statement.
Misrepresented (Case Law)

Brief claimed Lindke v. Freed overruled the district court on legislative immunity and that Lindke addressed legislative immunity; the court noted Lindke concerned social-media blocking and was mischaracterized.

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

Adverse Costs Order; Monetary Sanction; Potential disciplinary proceedings (monetary penalty: 30000 USD.)

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://reason.com/volokh/2026/03/14/lawyers-citing-nonexistent-cases-ordered-to-pay-opponents-attorney-fees-double-costs-15k-fine/, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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