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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Mark Lillard v. Offit Kurman, P.A.
SC Delaware · Mar 12, 2025
DE / stateEditorial impact: lowpro sefabricated quotesmisrepresented authoritytort
Direct answer
What happened in this matter?
Misrepresented: Case Law | Plaintiff cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization). Outcome: AI-use certification required for future filings.
- Why the court cared
- The record concerns whether quotations and pincites accurately matched the cited source. The tracked outcome is AI-use certification required for future filings; the linked source controls the precise reasoning.
- Why it matters now
- Delaware Superior Court is now requiring forward-looking AI certifications from pro-se litigants; expect the same for attorneys soon.
Why this matter is tracked
Misrepresented: Case Law | Plaintiff cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization). Outcome: AI-use certification required for future filings.
Operational lesson
Delaware Superior Court is now requiring forward-looking AI certifications from pro-se litigants; expect the same for attorneys soon.
Record details
DelawareSingle-state evidence scope
CourtSC Delaware
Jurisdictionstate
Circuit3rd Circuit
DateMar 12, 2025
UN
AI toolUnidentified
Party typePro Se Litigant
OutcomeAI-use certification required for future filings
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
not established
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Procedural posture
AI-use certification required for future filings
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.
- Misrepresented: Case Law | Plaintiff cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization).
- False Quotes: Case Law | Plaintiff cited a Delaware decision from the Dow Chemical litigation (42 Del. J. Corp. L 509, C.A. No. 12090-VCG (2018)) and attributed two specific quoted statements to it; the court could not find those quoted statements in that opinion.
- False Quotes: Case Law | Plaintiff referenced "Spence v. Spence" and attributed the quote “[d]ismissal is appropriate only if it is reasonably certain that the plaintiff could not prove any set of facts that would entitle him to relief.” Court located Spence v. Spence, 2012 WL 1495324 (Del. Super. Apr. 20, 2012) but the quoted language is not in that opinion; quote cannot be verified.
- Misrepresented: Case Law | Plaintiff cited E.E.C. v. E.J.C., 457 A.2d 688 (Del. 1983) to support standing because harm to a business flows to the owner; court noted E.E.C. concerns a divorce valuation of a husband's sole proprietorship and does not support Plaintiff's asserted proposition.
Questions this record answers
- What happened in Mark Lillard v. Offit Kurman, P.A.?
- Misrepresented: Case Law | Plaintiff cited Mattco Forge, Inc. v. Arthur Young & Co., 52 Cal.App.4th 820 (Ct. App. 1997) but used it to suggest conduct by an attorney; court found the case concerns an accountant, not an attorney (mischaracterization). Outcome: AI-use certification required for future filings.
- Why does Mark Lillard v. Offit Kurman, P.A. matter for legal AI risk?
- Delaware Superior Court is now requiring forward-looking AI certifications from pro-se litigants; expect the same for attorneys soon.
- What does the public record establish about Mark Lillard v. Offit Kurman, P.A.?
- The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Mark Lillard v. Offit Kurman, P.A. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; 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.