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Gittemeier v. Liberty Mutual Personal Insurance Company
E.D. Missouri · Nov 17, 2025
MS / federalEditorial impact: highfake citationsfabricated quotesmisrepresented authoritytrial
Direct answer
What happened in this matter?
Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition. Outcome: Costs Order + Fine; One Attorney ordered to withdraw. From the Order to Show Cause (available here): "One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No.…
- Why the court cared
- Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition. || Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Goodman v. Liberty Mut. Fire Ins. Co., 2022 WL 4534416 (E.D. Mo. Sept. 28, 2022)' to support its argument; the Court found the citation does not exist and the intended Goodman case did not support the asserted proposition. || Misrepresented: Case Law | Liberty Mutual mischaracterized and partially misquoted Dhyne v. State Farm, asserting it supported cooperation clauses and EUO requirements when the cited decision does not address those issues as claimed. || Misrepresented: Doctrinal Work | Liberty Mutual cited sections of 30 Mo. Prac., Insurance Law & Practice (§§ 4:2, 4:8, 4:9) as supporting that cooperation clauses/EUO requirements are longstanding and give rise to a presumption of prejudice; the Court found those sections do not contain the claimed statements and were mischaracterized.
- Why it matters now
- Blaming typos or vision impairment for AI hallucinations enrages courts — disclose the tool immediately when confronted.
Why this matter is tracked
Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition. Outcome: Costs Order + Fine; One Attorney ordered to withdraw. From the Order to Show Cause (available here): "One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No. 50].3 While the Court acknowledges Liberty Mutual’s prompt notice disclosing the two most serious errors in its filing, the additional misquotations and mischaracterizations discussed above will not be disregarded. Liberty Mutual indicates that the errors were typographical and/or caused by vision impairment, but that explanation is simply not credible. The errors in Liberty Mutual’s filing are not ones in which a few letters or numbers were passed over or shuffled. Rather, the filing includes entire names, dates, court designations, and Westlaw citations that are completely off base, and various other inaccuracies cannot be explained by typographical or vision issues. Therefore, the Court will reserve its ruling on the motion for sanctions and will set a hearing requiring Liberty Mutual to show cause why it should not be sanctioned."Later on, the court accepted Counsel's technical audit that suggested the errors stemmed from a human, non-AI source.
Operational lesson
Blaming typos or vision impairment for AI hallucinations enrages courts — disclose the tool immediately when confronted.
Record details
MississippiSingle-state evidence scope
CourtE.D. Missouri
Jurisdictionfederal
Circuit5th Circuit
DateNov 17, 2025
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeCosts Order + Fine; One Attorney ordered to withdraw
Known amount$1,000
Professional sanctionYes
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Costs Order + Fine; One Attorney ordered to withdraw
Correction behavior
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition.
- Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Goodman v. Liberty Mut. Fire Ins. Co., 2022 WL 4534416 (E.D. Mo. Sept. 28, 2022)' to support its argument; the Court found the citation does not exist and the intended Goodman case did not support the asserted proposition.
- Misrepresented: Case Law | Liberty Mutual mischaracterized and partially misquoted Dhyne v. State Farm, asserting it supported cooperation clauses and EUO requirements when the cited decision does not address those issues as claimed.
- Misrepresented: Doctrinal Work | Liberty Mutual cited sections of 30 Mo. Prac., Insurance Law & Practice (§§ 4:2, 4:8, 4:9) as supporting that cooperation clauses/EUO requirements are longstanding and give rise to a presumption of prejudice; the Court found those sections do not contain the claimed statements and were mischaracterized.
Questions this record answers
- What happened in Gittemeier v. Liberty Mutual Personal Insurance Company?
- Fabricated: Case Law | Liberty Mutual cited a non-existent case 'Chaudhri v. State Auto Prop. & Cas. Ins. Co., 2022 WL 4596697 (E.D. Mo. Sept. 30, 2022)'; the Court found the citation does not exist and the intended Chaudhri decision did not support the asserted proposition. Outcome: Costs Order + Fine; One Attorney ordered to withdraw. From the Order to Show Cause (available here): "One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No.…
- Why does Gittemeier v. Liberty Mutual Personal Insurance Company matter for legal AI risk?
- Blaming typos or vision impairment for AI hallucinations enrages courts — disclose the tool immediately when confronted.
- What does the public record establish about Gittemeier v. Liberty Mutual Personal Insurance Company?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Gittemeier v. Liberty Mutual Personal Insurance Company summary?
- The recorded source is reason.com. It is classified as secondary or other linked source; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.