Kingsfield / AI hallucination cases / Brooks and Brooks Inc. v. Patel et al.
VERDICT: REJECT

Brooks and Brooks Inc. v. Patel et al.

vLex / Fastcase. An invented case relied on across two briefs.

Court
Hennepin County DC, Minnesota
Decision date
2025-09-08
AI tool (per record)
vLex / Fastcase
Hallucination
Fabricated citation
Court outcome
Briefs stricken; Bar Referral; Monetary Sanction.
Monetary penalty
5000 USD
Kingsfield verdict
REJECT
In tested set
Yes

What happened

Rayandre Brooks sued Akshay Patel and several others in Hennepin County, Minnesota, claiming Patel agreed to sell him a gas station and convenience store business and then failed to transfer it. The defendants, represented by attorney David Lutz, moved for summary judgment.

While reviewing the defense briefs, the judge spotted suspicious quotations and citations. The motion brief and the reply brief both cited a 1996 Minnesota Court of Appeals decision, "Hallock v. Nelson, 545 N.W.2d 132," for language about part performance and the statute of frauds. That case does not exist. The citation number actually leads to a Nebraska Court of Appeals currency-forfeiture decision that has nothing to do with the lawsuit and contains none of the quoted language.

The court issued an order to show cause. Lutz responded in writing and at a hearing, admitting he used an AI research tool, VLex Fastcase, to draft both briefs and failed to confirm the Hallock citation. Plaintiff's counsel had never caught the fake case.

The fabricated citation

Hallock v. Nelson, 545 N.W.2d 132 (Minn. Ct. App. 1996)

Offered for: part-performance of a contract

What the court did

The court denied the summary judgment motion because of the fake caselaw and directed the administrator to strike both defense briefs. Judge Sande referred Attorney Lutz to the Minnesota Lawyer's Professional Responsibility Board and ordered him to pay a $5,000 penalty under Minn. R. Civ. P. 11.03 and Minn. Stat. 549.211, imposed on Lutz personally and not his client.

How Kingsfield ruled

Kingsfield returned REJECT. A nonexistent Minnesota decision, cited twice, with fabricated quotations attributed to it.

This matter is among the US case-law cases we ran Kingsfield against in the Charlotin benchmark. Kingsfield's existence check confirms every citation against the case-law corpus and an independent source (CourtListener) before any claim resting on it can stand. Across the run Kingsfield ruled 696 of 700 testable claims correctly, including every one of the 504 fabricated citations and 92 fabricated quotes.

Honest scope. This measures Kingsfield's ruling layer given an extracted citation, not an end-to-end run over a full brief. The case record and the AI-tool attribution come from Damien Charlotin's public database and the court order; the verdict is Kingsfield's. See the full 700-claim benchmark.

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