Gittemeier v. Liberty Mutual Personal Insurance Company
E.D. Missouri · Nov 17, 2025
- Jurisdiction
- federal
- Court
- E.D. Missouri
- Record ID
- gittemeier-v-liberty-mutual-personal-insurance-company-2025-11-17
- Observed outcome
- Costs Order + Fine; One Attorney ordered to withdraw
- Known monetary consequence
- $1,000
Why this matter warrants attention
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.…
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.
Blaming typos or vision impairment for AI hallucinations enrages courts — disclose the tool immediately when confronted.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- Trial
- Monetary
- Professional
- AI attribution
- Reported
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- $1,000
- Procedural posture
- Costs Order + Fine; One Attorney ordered to withdraw
reason.com
Secondary or other linked source. The recorded link is not classified as an official court source or docket mirror.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
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.
Latest evidence review: Secondary Source Only (medium confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Escalate and correct a suspect filing promptly, with a documented response.
- Assign a responsible reviewer for AI-assisted research and drafting.