Sanction teardown · S.D. Indiana, USA · 2026-05-26
William C. Maxwell v. Dakota Michael & Chelsey Smith
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:
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False Quotes (Case Law)Plaintiff presented 28 quotations attributed to real cases that do not appear in those cited opinions; Plaintiff admitted the quotes were incorrect, calling many 'paraphrases.' Court found this insufficient and included these false quotations in the Rule to Show Cause.
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Fabricated (Case Law)Plaintiff cited nine cases that do not appear to exist (non‑existent case citations); Court treated these as fabricated citations and included them in the Rule to Show Cause.
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
Monetary Sanction (monetary penalty: 1000 USD.)
Additional detail
Order to Show Cause is here.
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/2229/Maxwell_v._Michael_USA_26_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).