Sanction teardown · E.D. Wisconsin, USA · 2026-06-23
Xinyue Hippe v. Retention Brands, LLC
What happened
In E.D. Wisconsin, 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:
-
Misrepresented (Case Law)Sierra Club v. Franklin Cnty. Power of Ill. was cited to support that required accessibility fixes are 'modest in cost,' but the case concerns environmental permitting for a power plant and is unrelated to ADA or website accessibility.
-
Fabricated (Case Law)Plaintiff's counsel included entirely fabricated, nonexistent citations in paragraphs 16–17; court could not find cases supporting counsel's propositions and omitted the fabricated citations from the opinion.
-
Fabricated (Case Law)Citation(s) referencing a case involving 'Thrustmaster of America, Inc.' appear nonexistent; court found no federal case with that party.
-
Misrepresented (Case Law)Goodman v. Ill. Dep't of Fin. And Pro. Regul. was cited for the proposition that Title III of the ADA does not provide compensatory or punitive damages, but the case does not reference the ADA and does not support that proposition.
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
Order to Show Cause
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/2480/Hippe_v._Retention_Brand_USA_23_June_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).