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Withers v. City of Aberdeen

Court
N.D. Mississippi
Jurisdiction
USA
Decided
2026-06-08
AI tool
First Drafts
Outcome
Revoked pro hac vice; DQ resident attorneys from the case; Monetary Fine; Bar Referrals
Monetary penalty
8000 USD

What was hallucinated

Fabricated: Case Law | Defendant's memorandum [99] cited Miller v. City of Greenville, 243 So. 2d 81, 83 (Miss. 1971), which the Court could not locate and deemed hallucinatory. || Fabricated: Case Law | Defendant's memorandum [104] cited Riley v. City of Tupelo, No. 1:20-CV-186-GHD-DAS, 2023 WL 3568661, at 3 (N.D. Miss. May 18, 2023), which the Court could not verify. || Fabricated: Case Law | Defendant's memorandum [104] cited Buckner v. Walker, No. 1:19-CV-146-SA-DAS, 2022 WL 2318582, at 4 (N.D. Miss. June 28, 2022), which the Court determined was fabricated. || Fabricated: Case Law | Defendant's memorandum [104] cited Harris v. City of Grenada, No. 3:18-CV-158-DMB-RP, 2021 WL 6062574, at 7 (N.D. Miss. Dec. 22, 2021), which the Court could not locate. || Fabricated: Case Law | Plaintiff's opposition [105] contained two citations the Court found nonexistent, including City of Grenada v. Harrelson, 84 So. 3d 35, 38 (Miss. Ct. App. 2012). || Fabricated: Case Law | Plaintiff's opposition [105] cited Crittendon v. State Farm Mut. Auto. Ins. Co., 99 So. 3d 751, 755 (Miss. 2012), which the Court identified as a hallucinatory citation. || False Quotes: Case Law | Post-show-cause review disclosed a misrepresentation described as a 'fake quote' in one of Plaintiff's filings (court treated as a false quotation attributable to AI output).

Sanction teardown · N.D. Mississippi, USA · 2026-06-08

Withers v. City of Aberdeen

What happened

In N.D. Mississippi, USA, a filing relied on First Drafts to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Defendant's memorandum [99] cited Miller v. City of Greenville, 243 So. 2d 81, 83 (Miss. 1971), which the Court could not locate and deemed hallucinatory.
  • Fabricated (Case Law)
    Defendant's memorandum [104] cited Riley v. City of Tupelo, No. 1:20-CV-186-GHD-DAS, 2023 WL 3568661, at 3 (N.D. Miss. May 18, 2023), which the Court could not verify.
  • Fabricated (Case Law)
    Defendant's memorandum [104] cited Buckner v. Walker, No. 1:19-CV-146-SA-DAS, 2022 WL 2318582, at 4 (N.D. Miss. June 28, 2022), which the Court determined was fabricated.
  • Fabricated (Case Law)
    Defendant's memorandum [104] cited Harris v. City of Grenada, No. 3:18-CV-158-DMB-RP, 2021 WL 6062574, at 7 (N.D. Miss. Dec. 22, 2021), which the Court could not locate.
  • Fabricated (Case Law)
    Plaintiff's opposition [105] contained two citations the Court found nonexistent, including City of Grenada v. Harrelson, 84 So. 3d 35, 38 (Miss. Ct. App. 2012).
  • Fabricated (Case Law)
    Plaintiff's opposition [105] cited Crittendon v. State Farm Mut. Auto. Ins. Co., 99 So. 3d 751, 755 (Miss. 2012), which the Court identified as a hallucinatory citation.
  • False Quotes (Case Law)
    Post-show-cause review disclosed a misrepresentation described as a 'fake quote' in one of Plaintiff's filings (court treated as a false quotation attributable to AI output).

Which AI tool

First Drafts. 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

Revoked pro hac vice; DQ resident attorneys from the case; Monetary Fine; Bar Referrals (monetary penalty: 8000 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://www.damiencharlotin.com/documents/2371/Withers_v._City_of_Aberdeen_USA_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2371/Withers_v._City_of_Aberdeen_USA_June_2026.pdf

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