Kingsfield / AI hallucination cases / Williams v. Capital One Bank
VERDICT: REJECT

Williams v. Capital One Bank

Drafted with CoCounsel, the Westlaw legal-AI tool. Real-looking reporter, wrong on every part that matters.

Court
D. DC
Decision date
2025-03-18
AI tool (per record)
CoCounsel
Hallucination
Fabricated citation
Court outcome
Case dismissed with prejudice for failure to state a claim. No monetary sanction imposed, but the court issued a formal warning
Kingsfield verdict
REJECT
In tested set
Yes

What happened

Capital One closed Riyan Williams's credit card account. Williams, acting pro se, sued for breach of contract and for the bank's failure to give a reason for the closure under the Equal Credit Opportunity Act.

In his opposition to Capital One's motion to dismiss, Williams cited cases that do not exist, including Pettway v. American Savings & Loan Association, 197 F. Supp. 489 (N.D. Ala. 1961). He also cited Williams v. Equifax Information Services, a real case name, but with a reporter citation that points to a different case from the Northern District of California. Capital One's reply said it could find no such cases, and the filing appeared drafted with the help of an AI tool.

The fabricated citation

Pettway v. American Savings & Loan Association, 197 F. Supp. 489 (N.D. Ala. 1961)

Offered for: credit-card account closure and ECOA violations

What the court did

The Court granted the motion and dismissed the case with prejudice. On the citations, it stated that submitting authority that does not exist is unacceptable whether or not AI was used, strongly warned Williams against filing fabricated citations in this or any other court, and noted that if he followed the same practice in his other pending cases he must notify those courts and correct the citations. No monetary sanction was imposed.

How Kingsfield ruled

Kingsfield returned REJECT. No case by this name exists at that location. The reporter cite resolves to a different decision. The court confirmed no such case.

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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