AI Hallucination Cases

" Moreover, we take this opportunity to caution practitioners of this Commonwealth on the submission of briefs or citations without confirming their accuracy and the correctness of the resulting analysis. The abject failure to conduct due diligence when making arguments to the Court greatly impacts the profession and undermines confidence in the skills and knowledge necessary to practice as an attorney. Failure to verify substantive legal citations prior to submission to this Court is not only in derogation of the RAP, but also violates the attorney's ethical responsibilities. See Supreme Court Rule 3.130(1.1).

Mistakes occur. Oversights happen. Those types of inadvertent errors we could absolve. However, purposelessly submitting a brief to a Court of law without confirming that the cited case law even exists is an affront to the dignity of the Court system, the legal profession as a whole, the judiciary, the client, and the public at large."

The judge tested Microsoft M365 Copilot and found it produced fabricated Court of Appeal citations for Qdime and an incorrect citation for Gala Unity. The Tribunal concluded Mr Gurvits used AI-generated research without adequate verification; the AI outputs were rejected as unreliable. The Tribunal criticised the conduct but did not impose professional disciplinary sanctions; remedial orders in the case related to service charge and fee reimbursement.

The Board found over 70% of citations in Huffman's reply brief inaccurate, including fabricated cases, misattributed reporter citations, cases that did not support cited propositions, and incorrect or non-existent transcript/Rule 4 citations. Counsel admitted using AI to generate portions of the brief. The Board treated the motion as one for Rule 11-type sanctions and struck the reply brief; it emphasized attorneys' duty to verify AI-generated content.

The Court found 28 false or misleading citations across 11 pleadings (14 fabricated, 14 erroneous/misquoted). Mr. Howie admitted use of ChatGPT and failure to verify citations. The Court applied Rule 11(b) and its AI framework (verification, candor/correction, accountability) and imposed sanctions and restitution. Fines of 3,000, 2,000, and 1,000 USD on individual attorneys, plus opposing party's costs and fees,

The City argued—and the Court found—that the pro se plaintiff repeatedly cited nonexistent or inaccurately attributed caselaw likely generated by AI. The Court found these citations violated Rule 11, warned the plaintiff, and declined to award fees or impose sanctions. The court preserved the original incorrect citations in the opinion as part of the record.

The court was unable to locate one of the plaintiff's case citations and several quotations attributed to other cases; the court suspected portions of the filings were AI-generated and noted potential Rule 11 violations but did not impose sanctions.

Order to show cause is here.

Costs were awarded here.

"On September 3, 2025, Plaintiff filed his response to the court’s order to file copies of the cases he cited (#7). Therein, Plaintiff avers he took “concrete remedial steps” to cure the time wasted by his use of artificial-intelligence-hallucinated case citations, including “submission of the verified opinions as exhibits” (#7 at 2). Indeed, Plaintiff’s response stresses how he“obtained authentic copies” of those cases and “attached” them as exhibits. See (id.).

Plaintiff did not attach any exhibits to his response to this court’s order. The court is convinced that those two case citations are AI-hallucinated. Plaintiff’s insistence that they exist—and that he provided copies of them to this court—is bewildering."

(Not an hallucination per se, but worth adding to the database anyway.)

The Claimant used AI to generate case citations in his pleadings; Tribunal found 46 inaccurate or misleading citations (9 wholly fictitious, 37 misrepresentations of real cases) and concluded the conduct was reckless and unreasonable, justifying a costs order.

Folllowing a show cause order, Counsel admitted to having used the tool together with Google Search, and explained that, although he was aware of the issues with AI models like ChatGPT, he said he did not expect this tool to fall into the same issues.

The Court found Attorney James A. Johnson used Ghostwriter Legal to draft a motion that contained multiple fabricated case citations, misstated/false quotations attributed to authorities, and cited precedent that had been reversed by the Supreme Court. The Court found the conduct tantamount to bad faith and imposed sanctions under its inherent authority. Sanctions include an order to file, not under seal, this order "in any case in any court wherein he appears as counsel fortwelve (12) months after the date of this order."

The court noted prior fabricated citations in plaintiff's earlier briefing (for which counsel had already been sanctioned). In the current filing the court found no fabricated citations but identified inaccurate legal contentions—e.g., a rule statement claiming withholding ready-to-produce material while seeking extra time is sanctionable under Fed. R. Civ. P. 37(b)—which the court found unsupported and incorrect. The court suspected plaintiff used AI again, but simply removed the citations. The court admonished counsel to review AI-generated work and comply with Rule 11 but did not impose additional sanctions here.