Kingsfield / AI hallucination cases / Gustafson v. Amazon.com
VERDICT: REJECT

Gustafson v. Amazon.com

AI tool not identified in the record. A made-up case used to justify serving Amazon's foreign defendants by email.

Court
D. Arizona
Decision date
2025-04-30
AI tool (per record)
Not identified in the record
Hallucination
Fabricated citation
Court outcome
Warning
Kingsfield verdict
REJECT
In tested set
Yes

What happened

Stanley Gustafson sued Amazon.com and several Chinese entities in the District of Arizona. After the court denied his request for alternative service on the foreign defendants by email, he moved for reconsideration, arguing the Hague Service Convention permits email service and that traditional service would be too slow and costly.

To support the claim that the Convention allows email service, Gustafson cited a case that does not exist. He also told the court that a February 18, 2025 letter, attached as "Exhibit A," showed an attorney named Sophia confirming she represented all four foreign defendants. No such letter was attached, and the letter that was in the record stated Sophia represented only one defendant.

The fabricated citation

Graham v. Nyquist (no reporter or page)

Offered for: that the Hague Service Convention permits service by email

What the court did

The court denied the motion for reconsideration as untimely and as a rehash of prior arguments, and found Gustafson had not shown manifest error. In a footnote, it admonished him that he is subject to Rule 11, which authorizes sanctions for citation to non-existent caselaw, and that parties must confirm the existence and validity of the authorities they cite.

How Kingsfield ruled

Kingsfield returned REJECT. No decision called Graham v. Nyquist exists, and the cite carries no reporter to resolve. The court warned of Rule 11 sanctions.

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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