USA v. Burke
M.D. Florida · May 15, 2025
- Jurisdiction
- federal
- Court
- M.D. Florida
- Record ID
- usa-v-burke-2025-05-15
- Observed outcome
- The court struck the motion to dismiss and ordered the defendant to refile a corrected version accompanied by an explanation from counsel regarding the errors.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court struck the defendant's motion to dismiss due to pervasive citation errors, including fabricated quotes and misrepresented case law. The court ordered the defendant to refile the motion and required counsel to provide a written explanation regarding the source of these errors and future preventative measures.
The record concerns whether quotations and pincites accurately matched the cited source. The tracked outcome is Motion dismissed, and plaintiff ordered to refile it without fake citations.; the linked source controls the precise reasoning.
Paid tools like Westlaw AI and GPT Pro still hallucinate quotes; independently pull every quotation from the underlying opinion.
Failure modes and consequences
- Fabricated Quotes
- Misrepresented Authority
- Criminal
- Trial
- Case Dismissed
- AI attribution
- Reported
- Recorded tool
- Westlaw's AI tools, GPT4.5 Deep Research (Pro)
- Known monetary consequence
- Not recorded
- Procedural posture
- The court struck the defendant's motion to dismiss (Doc. 119) and ordered the defendant to refile a corrected motion by May 19, 2025.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
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
Westlaw's AI tools, GPT4.5 Deep Research (Pro) is recorded in the source dataset; confirm the basis in the linked document.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Independently verify every case citation, quote, and pincite against the original source document.
- Confirm that cited authorities actually support the specific legal propositions for which they are invoked.
- Implement rigorous internal review processes for all filings to detect and correct potential hallucinations or misrepresentations.
- Ensure counsel maintains direct oversight of research outputs to prevent the submission of inaccurate or fabricated legal authority.