1. The Crime Scene (The Symptom)
Counsel filed a motion citing three state appellate decisions to support a novel theory of algorithmic liability. All three opinions were generated by a commercial legal-research AI assistant and inserted into the brief without independent verification. Opposing counsel flagged the citations; the court ordered sanctions briefing.
A production legal-AI wrapper returned fabricated state appellate opinions with realistic-looking docket numbers and neutral citations — indistinguishable from real authority on a surface read.
2. The Artifact (Raw LLM Output)
"In Kistler v. LegalTech Corp., 412 P.3d 891 (Colo. App. 2023), the court held
that a vendor owes a duty of reasonable care when marketing AI-generated legal
research as 'court-validated' where the output is used in filed pleadings..."
"See also Hartwell v. DataLex Systems, 198 A.3d 445 (Pa. Super. Ct. 2022)
(applying a negligence-per-se standard to uncited AI outputs in probate filings)."
"Compare Morales v. BriefBot Inc., 387 So. 3d 112 (Fla. Dist. Ct. App. 2024)
(reversing dismissal where plaintiff alleged reliance on AI-generated precedent)."
3. The Evidence Breakdown (The Core Contradiction)
Claimed Authority: Kistler v. LegalTech Corp., 412 P.3d 891 (Colo. App. 2023).
The Reality Check: Colorado Court of Appeals published opinions for 2023 contain no case by this caption at 412 P.3d 891. The case name mirrors the instant litigation — a classic LLM confabulation pattern.
Claimed Authority: Hartwell v. DataLex Systems, 198 A.3d 445 (Pa. Super. Ct. 2022).
The Reality Check: Pennsylvania Superior Court reports show no matching entry. The "negligence-per-se" holding is syntactically coherent but jurisprudentially invented.
Pattern: Vendor UI presented outputs with confidence formatting ("Verified Cases") while underlying model produced entirely novel authorities. Link-checking tools that only validate URL structure would not catch this failure class.
4. The Dali Verification Check
Dali existence audit: 3/3 cited authorities fail canonical lookup across Colorado, Pennsylvania, and Florida reporter indices. Severity escalates to Critical because all citations supported dispositive motion arguments.