ChatGPT. A made-up case name and a fake quote in the same filing.
Harvey, an unrepresented plaintiff, sued Torrent Leasing and U.S. Bank in the District of Nevada over a garnishment, anchoring federal jurisdiction on a Section 1983 claim that the two private companies deprived him of exempt property without due process. U.S. Bank moved to dismiss, pointing out that neither defendant is a state actor.
U.S. Bank also flagged that several cases in Harvey's briefs were miscited or misquoted. He cited Flangas v. Perfekt Marketing, but the citation he gave corresponds instead to Lawrence v. Clark County. He also included a fake quote from the since-overruled Seventh Circuit decision Nesses v. Shepard. The court linked the pattern to generative AI tools like ChatGPT, which can pull from unreliable sources and make up fake legal authority.
Offered for: supporting authority in the brief
Judge Jennifer A. Dorsey granted the motion to dismiss, dismissed the Section 1983 claim with prejudice, declined supplemental jurisdiction over the state-law claims, denied leave to amend as futile, and entered judgment for the defendants. In a separate section, the court cautioned that using AI tools may violate Rule 11 and may result in sanctions for continued reliance on inaccurate or fake authority.
Kingsfield returned REJECT. The named case is fabricated and a quotation attributed to Nesses v. Shepard appears nowhere in that opinion. The provided cite actually points to Lawrence v. Clark County.
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.