1. The Crime Scene (The Symptom)
In Mata v. Avianca, Inc., counsel submitted a brief containing six judicial opinions that did not exist. The citations were produced by ChatGPT and presented as real authority without verification. The court found the conduct sanctionable and issued a show-cause order.
The system generated non-existent judicial decisions — complete with reporter citations, court names, and holdings — to support an affirmation opposing dismissal on statute-of-limitations grounds.
2. The Artifact (Raw LLM Output)
"Varghese v. China Southern Airlines Co., Ltd., 925 F.3d 1339 (11th Cir. 2019) —
The court held that the Montreal Convention's two-year limitation period is
tolled during the pendency of a bankruptcy proceeding..."
"Martinez v. Delta Air Lines, Inc., 932 F. Supp. 2d 758 (S.D.N.Y. 2013) —
The court found that a personal injury action under the Montreal Convention
was timely filed where the plaintiff's injuries manifested after landing..."
"Zicherman v. Korean Air Lines Co., Ltd., 516 U.S. 217 (1996) —
The Supreme Court held that the Montreal Convention preempts state law
limitations periods in aviation personal injury actions..."
3. The Evidence Breakdown (The Core Contradiction)
Claimed Authority: Varghese v. China Southern Airlines, 925 F.3d 1339 (11th Cir. 2019).
The Reality Check: Volume 925 of the Federal Reporter 3d does not contain page 1339. No 11th Circuit docket matches this case title or holding from 2019. The citation format is plausible; the authority is entirely fabricated.
Claimed Authority: Martinez v. Delta Air Lines, 932 F. Supp. 2d 758 (S.D.N.Y. 2013).
The Reality Check: No such case appears in the Federal Supplement 2d at that citation. The S.D.N.Y. docket index shows no matching disposition.
Pattern: Each hallucination follows correct Bluebook surface structure — party names, reporter series, court, year — while failing existence checks at every layer: docket, reporter volume/page, and holding text.
4. The Dali Verification Check
Canonical mismatch: reporter volume 925 F.3d page 1339 resolves to no published opinion. Dali's existence pass flags authority_not_found before any semantic proposition check runs — the failure mode is total fabrication, not misread text.