Benchmark
The problem, in numbers
| Court cases involving fake citations, 2023–2026 | 2,041 (as of 14 Sept 2026) |
| New cases per day, mid-2026 | about 8 |
| Largest single penalty so far | about $110,000 |
| Fake citations named in the 30 orders we tested | 64 |
| — invented case | 34 |
| — real case, wrong address | 15 |
| — real case, invented quote | 15 |
| Of those 64, the kind an “is it real?” check can catch | 34 |
What the usual check misses, and what Cite11 caught
| Type of fake citation | The usual check: “does the case exist?” | Cite11, in this test |
|---|---|---|
| Invented case | Catches it | Caught 22 of 22 |
| Real case, wrong address | Misses it — the case exists | Caught 9 of 10 |
| Real case, invented quote | Misses it — the case exists | Not yet tested |
And on the other side of the ledger: of 65 real citations in the same filings, Cite11 confirmed 46, said “can't check” on 11, and warned in error on 5. It has never marked a fake citation as real: 0 of 49, in five runs.
Three other citation checkers are on the market — CiteCheck AI, CiteSentinel, GroundTruth. None has published test results.
Where the 136 came from
Damien Charlotin's public database lists 2,041 court cases involving AI-fabricated citations as of 14 September 2026. Most orders say “counsel cited nonexistent cases” without listing them. Thirty-five name the citations in writing; thirty could be checked against the order's own text. That gave 136 citations, each carrying the judge's finding.
Source: AI Hallucination Cases Database, Damien Charlotin, https://www.damiencharlotin.com/hallucinations/ — licensed CC BY 4.0.
The one miss (out of 49)
| Citation as filed | What Cite11 said | Why |
|---|---|---|
| Menocal — a bare name, no reporter | Could not be checked | Nothing to look up. Cite11 won't guess at a lone word. |
The five false warnings
| Citation as filed | What Cite11 said | Why |
|---|---|---|
| Cooter & Gell v. Hartmax Corp., 496 U.S. 384 | Address mismatch | The brief itself misspelled Hartmarx. |
| Mars Steel Corp. v. Cont'l Bank N.A., 880 F.2d 928 | Address mismatch | The official caption adds four more parties. On the fix list. |
| Mata v. Avianca, 678 F. Supp. 3d 443 (cited four times) — not yet in CourtListener | Not found | Too recent for the public index. |
| Williams v. The Ests. LLC, 663 F. Supp. 3d 466 — not yet in CourtListener | Not found | Too recent for the public index. |
| Malkeet Lnu v. Blanche, 177 F.4th 1014 — not yet in CourtListener | Not found | Too recent for the public index. |
What wasn't tested
Fifteen invented quotations, because the test sentences carried no quoted text. Seventeen fake and seven real citations were Westlaw or LEXIS numbers or very recent opinions, which are not in the public record; Cite11 reported “outside coverage” rather than guess. Four real citations were not checked.
Every citation we tested
136 citations, grouped by the order they came from, each with the court's finding and Cite11's result.
Mata v. Avianca, Inc
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Varghese v. China Southern Airlines Co., Ltd., 925 F.3d 1339 (11th Cir. 2019) | Invented case | Not found | Match |
| Shaboon v. Egyptair, 2013 IL App (1st) 111279-U (Ill. App. Ct. 2013) | Invented case | Not found | Match |
| Peterson v. Iran Air, 905 F. Supp. 2d 121 (D.D.C. 2012) | Invented case | Address mismatch | Match |
| Martinez v. Delta Airlines, Inc., 2019 WL 4639462 (Tex. App. Sept. 25, 2019) | Invented case | Outside coverage | Not tested |
| Estate of Durden v. KLM Royal Dutch Airlines, 2017 WL 2418825 | Invented case | Outside coverage | Not tested |
| Miller v. United Airlines, Inc., 174 F.3d 366, 371-72 (2d Cir. 1999) | Invented case | Address mismatch | Match |
| Muhammad v. Walmart Stores East, L.P., 732 F.3d 104, 108 (2d Cir. 2013) | Real citation | Could not be checked | Not tested |
| Cooter & Gell v. Hartmax Corp., 496 U.S. 384, 398 (1990) | Real citation | Address mismatch | Miss |
| Fishoff v. Coty Inc., 634 F.3d 647, 654 (2d Cir. 2011) | Real citation | Verified | Match |
Ex Parte Lee
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Ex parte Vasquez, 248 S.W.3d 454 (Tex. Crim. App. 2008) | Real case, wrong address | Address mismatch | Match |
| Ex parte Clayton, 592 S.W.2d 494 (Tex. Crim. App. 1979) | Real case, wrong address | Address mismatch | Match |
| Ex parte Martinez, 340 S.W.3d 642 (Tex. Crim. App. 2011) | Real case, wrong address | Address mismatch | Match |
| Neville v. State, 622 S.W.3d 99, 104 (Tex. App.—Waco 2020, no pet.) | Real citation | Outside coverage | Not tested |
Frier v. Hingiss
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Ratzlaf v. Nordstrom, Inc., 968 F.2d 946, 950 (7th Cir. 1992) | Real case, wrong address | Address mismatch | Match |
| Palka v. City of Chicago, 662 F.3d 428 (7th Cir. 2011) | Real case, invented quote | Verified | Not tested |
| King v. Ill. State Bd. of Elections, 410 F.3d 404, 423 (7th Cir. 2005) | Real citation | Verified | Match |
| Mars Steel Corp. v. Cont’l Bank N.A., 880 F.2d 928, 938 (7th Cir. 1989) | Real citation | Address mismatch | Miss |
Zachariah Crabill Disciplinary Case
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| In re Fisher, 202 P.3d 1186, 1202 (Colo. 2009) | Real citation | Verified | Match |
Matter of Samuel
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Matter of Rottkamp, 95 AD3d 1338, 1339-1340 [2d Dept 2012] | Real citation | Verified | Match |
Park v. Kim
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014) | Invented case | Address mismatch | Match |
| Wolters Kluwer Fin. Servs., Inc. v. Scivantage, 564 F.3d 110, 113 (2d Cir. 2009) | Real citation | Could not be checked | Not tested |
In re Thomas Grant Neusom
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 395 (1990) | Real citation | Verified | Match |
| Law Sols. of Chicago LLC v. Corbett, 971 F.3d 1299, 1316 (11th Cir. 2020) | Real citation | Verified | Match |
Michael Cohen Matter
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| United States v. Figueroa-Florez, 64 F.4th 223 (2d Cir. 2022) | Invented case | Not found | Match |
| United States v. Ortiz, (No. 21-3391), 2022 WL 4424741 (2d Cir. Oct. 11, 2022) | Invented case | Outside coverage | Not tested |
| United States v. Amato, 2022 WL 1669877 (2d Cir. May 10, 2022) | Invented case | Outside coverage | Not tested |
| United States v. Lussier, 104 F.3d 32, 35 (2d Cir. 1997) | Real citation | Verified | Match |
Grant v. City of Long Beach
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Smith v. City of Oakland, 731 F.3d 1222, 1231 (11th Cir. 2013) | Invented case | Address mismatch | Match |
| Jones v. Williams, 791 F.2d 1024 (9th Cir. 1986) | Invented case | Address mismatch | Match |
| Hydrick v. Hunter, 669 F.3d 937 (9th Cir. 2012) | Real citation | Verified | Match |
| Wall v. County of Orange, 364 F.3d 1107 (9th Cir. 2004) | Real citation | Verified | Match |
| Sekiya v. Gates, 508 F.3d 1198, 1200 (9th Cir. 2007) | Real citation | Verified | Match |
Rasmussen v. Rasmussen
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Kerrigan v. O’Meara, (1926) 71 Cal.App. 346 | Invented case | Address mismatch | Match |
| Dino v. Pelliccioni, (1962) 200 Cal.App.2d 163, 170 | Real case, wrong address | Address mismatch | Match |
| Cummings v. Dessel, (2017) 13 Cal.App.5th 589 | Real citation | Verified | Match |
USA v. Michel
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Strickland v. Washington, 466 U.S. 668 | Real citation | Verified | Match |
| United States v. Cronic, 466 U.S. 648 | Real citation | Verified | Match |
| Hemphill v. New York, 595 U.S. 140 | Real citation | Verified | Match |
Iovino v. Michael Stapleton Associates, Ltd.
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| United Therapeutics Corp. v. Watson Labs, Inc., 2017 WL 2483620 | Invented case | Outside coverage | Not tested |
| United States v. Mosby, 2021 WL 2827893 | Invented case | Outside coverage | Not tested |
| Menocal, 113 F. Supp. 3d 1125 | Real case, wrong address | Could not be checked | Miss |
| Graves v. Lioi, 930 F.3d 307 | Real case, invented quote | Verified | Not tested |
| Bostock v. Clayton Cnty., 590 U.S. 644 | Real case, invented quote | Verified | Not tested |
| Mescall v. Renaissance at Antiquity, 2023 WL 7490841 | Real citation | Outside coverage | Not tested |
Matter of Weber
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Frye v. United States, 293 F. 1013 | Real citation | Verified | Match |
| People v. Wakefield, 38 NY3d 367 | Real citation | Outside coverage | Not tested |
Thomas v. Commissioner of Internal Revenue
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Schluter v. Commissioner, T.C. Memo 1998-269 | Real case, wrong address | Outside coverage | Not tested |
| Meneguzzo v. Commissioner, T.C. Memo 1969-15 | Real case, wrong address | Outside coverage | Not tested |
| Gagliardi v. Commissioner, T.C. Memo 2011-194 | Real case, wrong address | Address mismatch | Match |
| Dynamo Holdings L.P. v. Commissioner, 143 T.C. 183 | Real citation | Verified | Match |
Mortazavi v. Booz Allen Hamilton, Inc.
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Hudson v. Moore Bus. Forms, Inc., 836 F.2d 1156 | Real citation | Verified | Match |
| Ayers v. City of Richmond, 895 F.2d 1267 | Real citation | Verified | Match |
| Bus. Guides, Inc. v. Chromatic Commc'ns Enterprises, Inc., 498 U.S. 533 | Real citation | Verified | Match |
| Yagman v. Republic Ins., 987 F.2d 622 | Real citation | Verified | Match |
Berry v. Stewart
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Hogan v. Allstate Insurance Co., 2020 WL 1882334 | Invented case | Outside coverage | Not tested |
Gauthier v. Goodyear Tire & Rubber Co.
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Roca v. King's Creek Plantation, LLC, 500 F. App'x 273 | Invented case | Address mismatch | Match |
| Beets v. Texas Instruments, Inc., 1994 WL 714026 | Invented case | Outside coverage | Not tested |
| Morales v. SimuFlite Training Int'l, Inc., 132 S.W.3d 603 | Real case, invented quote | Verified | Not tested |
| White v. FCI USA, Inc., 319 F.3d 672 | Real case, invented quote | Verified | Not tested |
| Burton v. Freescale Semiconductor, Inc., 798 F.3d 222 | Real case, invented quote | Verified | Not tested |
| Texas Dep't of Human Servs. v. Hinds, 904 S.W.2d 629 | Real case, invented quote | Verified | Not tested |
| Physio GP, Inc. v. Naifeh, 306 S.W.3d 886 | Real case, invented quote | Verified | Not tested |
| City of Midland v. O'Bryant, 18 S.W.3d 209 | Real case, invented quote | Verified | Not tested |
| Park v. Kim, 91 F.4th 610 | Real citation | Verified | Match |
| Mata v. Avianca, Inc., 678 F. Supp. 3d 443 | Real citation | Not found | Miss |
| Iovino v. Michael Stapleton Assocs., Ltd., 2024 WL 3520170 | Real citation | Outside coverage | Not tested |
Kohls v. Ellison
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 | Real citation | Verified | Match |
| Acosta v. Mezcal, Inc., 2019 WL 2550660 | Real citation | Outside coverage | Not tested |
| In re World Trade Ctr. Disaster Site Litig., 722 F.3d 483 | Real citation | Verified | Match |
| Morgan v. Cmty. Against Violence, 2023 WL 6976510 | Real citation | Outside coverage | Not tested |
Gonzalez v. Texas Taxpayers and Research Association
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Bloomberg L.P. v. Bd. of Govs. of the Fed. Reserve Sys., 649 F. 3d 651 | Invented case | Not found | Match |
| Hogan v. AT&T, Inc., 917 F. Supp. 1275 | Invented case | Address mismatch | Match |
| Head v. Chicora Life Ctr., LLC, 290 F. Supp. 3d 883 | Invented case | Address mismatch | Match |
| Cruz v. Aramark Servs., Inc., 213 F. Supp. 2d 135 | Real case, wrong address | Address mismatch | Match |
| TIG Ins. Co. v. Carter, 640 S.W. 2d 232 | Real case, wrong address | Address mismatch | Match |
| Chambers v. NASCO, 501 U.S. 32 | Real citation | Verified | Match |
| Crowe v. Smith, 151 F.3d 217 | Real citation | Verified | Match |
| Edwards v. General Motors Corp., 153 F.3d 242 | Real citation | Verified | Match |
Wadsworth v. Walmart (Morgan & Morgan)
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Collins v. Daniels, 916 F.3d 1302 | Real citation | Verified | Match |
| Mata v. Avianca, Inc., 678 F. Supp. 3d 443 | Real citation | Not found | Miss |
| Williams v. The Ests. LLC, 663 F. Supp. 3d 466 | Real citation | Not found | Miss |
| In re Keegan Mgmt. Co., Sec. Litig., 78 F.3d 431 | Real citation | Verified | Match |
Bunce v. Visual Technology Innovations (1)
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| McNally v. Eyeglass World, LLC, 897 F. Supp. 2d 1067 | Invented case | Address mismatch | Match |
| Behm v. Lockheed Martin Corp., 460 F.3d 860 | Invented case | Address mismatch | Match |
| Degen v. United States, 517 U.S. 820 | Real citation | Verified | Match |
| Dow Chemical Canada Inc. v. HRD Corp., 259 F.R.D. 81 | Real citation | Verified | Match |
| Eavenson, Auchmuty Greenwald v. Holtzman, 775 F.2d 535 | Real citation | Verified | Match |
| Gaiardo v. Ethyl Corp., 835 F.2d 479 | Real citation | Verified | Match |
| Comuso v. Nat'l R.R. Passenger Corp., 267 F.3d 331 | Real citation | Verified | Match |
| Cunningham v. Hamilton Cnty., Ohio, 527 U.S. 198 | Real citation | Could not be checked | Not tested |
Dehghani v. Castro
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Moncada v. Ruiz, 518 F. Supp 3d 708 (D.N.M. 2021) | Invented case | Not tested — not extracted from the source text | Not tested |
| Vega-Mendoza v. Homeland Security, 382 F. Supp 3d 1209 (D.N.M. 2019) | Invented case | Not tested — not extracted from the source text | Not tested |
| Morales v. ICE Field Office Director, 541 F. Supp 3d 1154 (D.N.M. 2021) | Invented case | Not tested — not extracted from the source text | Not tested |
| Meza v. United States Attorney General, 130 F. Supp. 3d 1052 (N.D. Tex. 2015) | Invented case | Address mismatch | Match |
| Hernandez v. Sessions, 298 F. Supp. 3d 1366 (D.N.M. 2018) | Invented case | Address mismatch | Match |
| Ramirez v. DHS, 338 F. Supp. 3d 1 (D.N.M. 2020) | Invented case | Address mismatch | Match |
| Adamson v. Bowen, 855 F.2d 668, 672 (10th Cir. 1988) | Real citation | Verified | Match |
| Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 461 (S.D.N.Y. 2023) | Real citation | Not found | Miss |
| Wadsworth v. Walmart Inc., 2025 WL 608073, at *4 (D. Wyo. Feb. 24, 2025) | Real citation | Outside coverage | Not tested |
Bevins v. Colgate-Palmolive Co.
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Tinch v. Video Indus. Servs., Inc., No. 1712 EDA 2018, 2019 WL 1396975, at *3 (Pa. Super. Ct. Mar. 27, 2019) | Real case, wrong address | Outside coverage | Not tested |
| Burton v. Danek, No. 95-5560, 1997 WL 436713, at *8 (E.D. Pa. July 31, 1997) | Real case, wrong address | Outside coverage | Not tested |
| Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007) | Real citation | Verified | Match |
| Napier v. Thirty or More Unidentified Fed. Agents, Emps. or Officers, 855 F.2d 1080, 1091 (3d Cir. 1988) | Real citation | Could not be checked | Not tested |
Benjamin v. Costco Wholesale Corp
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Klein v. E. I. Du Pont de Nemours & Co., 406 F.2d 1004, 1006 (2d Cir. 1969) | Invented case | Address mismatch | Match |
| Gordon v. N.Y. Cent. R.R. Co., 202 F. Supp. 2d 290, 292 (W.D.N.Y. 2002) | Invented case | Address mismatch | Match |
| Mitchell v. JCG Industries, 2010 WL 11627832, at *3 (N.D. Ill. Dec. 1, 2010) | Invented case | Outside coverage | Not tested |
| Hollander v. Sweeney, 2005 WL 19904045, at *3 (S.D. Ind. Aug. 17, 2005) | Invented case | Outside coverage | Not tested |
| Davis v. S. Farm Bureau Cas. Inc. Co., 2019 WL 3452601, at *2 (W.D. Ark. July 31, 2019) | Invented case | Outside coverage | Not tested |
| Park v. Kim, 91 F.4th 610, 614 (2d Cir. 2024) | Real citation | Verified | Match |
| Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 459 (S.D.N.Y. 2023) | Real citation | Not found | Miss |
Flowz Digital LLC v. Caroline Dalal
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Shell Petroleum N.V. v. Republic of Costa Rica, 608 F. Supp. 2d 269 (S.D.N.Y. 2009) | Invented case | Address mismatch | Match |
| In re Daou Systems, Inc., 411 F.3d 1006 (9th Cir. 2005) | Real citation | Verified | Match |
| S.E.C. v. Cross Financial Services, Inc., 908 F. Supp. 718 (C.D. Cal. 1995) | Real citation | Verified | Match |
Lacey v. State Farm General Insurance
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Booth v. Allstate Ins. Co., 198 Cal.App.3d 1357, 1366 (1989) | Invented case | Outside coverage | Not tested |
| National Steel Products Co. v. Superior Court, 164 Cal.App.3d 476, 489 (1985) | Real case, invented quote | Verified | Not tested |
| Chambers v. NASCO, Inc., 501 U.S. 32, 46-47 (1991) | Real citation | Verified | Match |
| Fink v. Gomez, 239 F.3d 989, 994 (9th Cir. 2001) | Real citation | Verified | Match |
Capital Standard, LLC v. U.S. Bank National Association
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Board of Regents v. Wilson, 365 So. 2d 213 (Fla. 1st DCA 1979) | Invented case | Address mismatch | Match |
| Maciejewski v. Holland, 441 So. 2d 703 (Fla. 2d DCA 1983) | Real case, invented quote | Verified | Not tested |
| Hart Properties, Inc. v. Slack, 159 So. 2d 236, 239 (Fla. 1963) | Real case, wrong address | Address mismatch | Match |
| Miami Country Day School v. Bakst, 641 So. 2d 467 (Fla. 3d DCA 1994) | Real case, invented quote | Verified | Not tested |
| Gonzalez v. Deutsche Bank National Trust Co., 95 So. 3d 251 (Fla. 2d DCA 2012) | Real case, invented quote | Verified | Not tested |
| Malkeet Lnu v. Blanche, 177 F.4th 1014, 1024 (9th Cir. 2026) | Real citation | Not found | Miss |
Michael L. Ruiz v. Magellan Financial & Insurance Services
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Antonakeas, (Ninth Circuit case, full citation withheld by court) | Real case, invented quote | Not tested — citation withheld by the court | Not tested |
| Osazuwa, (Ninth Circuit case, full citation withheld by court) | Real case, invented quote | Not tested — citation withheld by the court | Not tested |
| Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003) | Real citation | Verified | Match |
| In re Girardi, 611 F.3d 1027, 1038 (9th Cir. 2010) | Real citation | Verified | Match |
Adams v. Matrix Providers Inc. et al.
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Ricks v. Starbucks, No. 21-cv-01386, 2023 WL 8872476, at *6 (D. Colo. Dec. 22, 2023) | Real case, wrong address | Outside coverage | Not tested |
| Tabura v. Kellogg USA, 880 F.3d 544, 549 (10th Cir. 2018) | Real citation | Verified | Match |
| Servants of the Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000) | Real citation | Verified | Match |
Douglas v. Deutsche Bank National Trust Company
| Citation as filed | What the court found | What Cite11 reported | Match or miss |
|---|---|---|---|
| Abadie v. District of Columbia, Abadie v. District of Columbia | Invented case | Not tested — citation withheld by the court | Not tested |
| Cason v. Nat'l Consumer Co-op Bank, Cason v. Nat'l Consumer Co-op Bank | Invented case | Not tested — citation withheld by the court | Not tested |
| Osborne v. District of Columbia, Osborne v. District of Columbia | Invented case | Not tested — citation withheld by the court | Not tested |
| Woods v. United States, Woods v. United States | Invented case | Not tested — citation withheld by the court | Not tested |
| Grant v. City of Long Beach, 96 F.4th 1255, 1256-57 (9th Cir. 2024) | Real citation | Verified | Match |
| United States v. Jones, 744 F.3d 1362, 1370 n.2 (D.C. Cir. 2014) | Real citation | Verified | Match |
The bottom line
A citation can be wrong in three ways: the case doesn't exist, the case exists but the number points somewhere else, or the case exists but the quoted words aren't in it. The first is easy to catch. The other two pass the “does it exist?” check every time, and they are now most of what courts are sanctioning. Cite11 checks all three against the public court record and tells you, for each citation, which one it found — or that it couldn't check. On the citations judges have already ruled on, it has never called a fake one real, it caught all but one it could see, and it warned about one real citation in twelve. That is what a Verification Report certifies: not that your brief is right, but that every citation in it was checked, dated, and numbered before you signed.