Skip to main content
Citation Safe

Was William Parker on the other side of your case?

Check their next brief before they file — Opposition Check verifies every citation in a filed brief for $49, no signup. Get Opposition Check →

William Parker v. Patrick "Pat" Labat, et al.

Court
N.D. Georgia
Jurisdiction
USA
Decided
2026-01-21
AI tool
Unidentified
Outcome
CLE; Sworn statement
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Court found a cited case does not exist and counsel cited it as Eleventh Circuit authority. || False Quotes: Case Law | Court determined the language counsel attributed to the Fourth Circuit's Akers opinion does not appear in that decision. || False Quotes: Case Law | Court found counsel quoted language that does not appear in Cutliffe and relied on that misquotation. || False Quotes: Case Law | Court found the quoted passage counsel attributed to Underwood does not appear in that opinion and the reliance was misplaced. || False Quotes: Case Law | Court found the passage counsel attributed to Randall does not appear in that opinion. || Misrepresented: Case Law | Court concluded counsel misstated the holding of Reeves, treating an ADEA decision as establishing a constitutional right. || Misrepresented: Case Law | Court found counsel relied on Moss in support of a sheriff-deputy patronage argument, but Moss involved a firefighter and did not apply the Elrod-Branti analysis.

Details

While the R&R recommended a monetary sanction, in the eventual order (available here), the court opted only for six hours of CLE, and the requirement of a "sworn statement with every document [Counsel] files in this Court verifying that [Counsel] has personally checked all citations and quotations in the filing to ensure accuracy."

Sanction teardown · N.D. Georgia, USA · 2026-01-21

William Parker v. Patrick "Pat" Labat, et al.

What happened

In N.D. Georgia, 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)
    Court found a cited case does not exist and counsel cited it as Eleventh Circuit authority.
  • False Quotes (Case Law)
    Court determined the language counsel attributed to the Fourth Circuit's Akers opinion does not appear in that decision.
  • False Quotes (Case Law)
    Court found counsel quoted language that does not appear in Cutliffe and relied on that misquotation.
  • False Quotes (Case Law)
    Court found the quoted passage counsel attributed to Underwood does not appear in that opinion and the reliance was misplaced.
  • False Quotes (Case Law)
    Court found the passage counsel attributed to Randall does not appear in that opinion.
  • Misrepresented (Case Law)
    Court concluded counsel misstated the holding of Reeves, treating an ADEA decision as establishing a constitutional right.
  • Misrepresented (Case Law)
    Court found counsel relied on Moss in support of a sheriff-deputy patronage argument, but Moss involved a firefighter and did not apply the Elrod-Branti analysis.

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

CLE; Sworn statement

Additional detail

While the R&R recommended a monetary sanction, in the eventual order (available here), the court opted only for six hours of CLE, and the requirement of a "sworn statement with every document [Counsel] files in this Court verifying that [Counsel] has personally checked all citations and quotations in the filing to ensure accuracy."

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/1483/Parker_v._Labat_USA_21_January_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1483/Parker_v._Labat_USA_21_January_2026.pdf

Don’t be the next case in this database.

Citation Safe checks every citation against primary sources before it reaches a filing.

Try the free checkerBack to database

On the opposing side of their next motion?

Check their next brief through the same engine that would have caught this filing — $49, no signup, full annotated report you can attach to your Rule 11 or sanctions motion.

Open Opposition Check — $49Sanctions-motion template