AI Hallucination Cases

AI Use

Although AI was not named and Plaintiff denied intentional fabrication, the court considered the citation (Adamov, 779 F.3d 851, 860 (8th Cir. 2015)) to be plainly fictitious. It noted the possibility that Plaintiff used generative AI tools, given the fabricated citation's plausible-sounding structure and mismatch with existing precedent.

Hallucination Details

Plaintiff submitted fabricated legal authorities in at least two filings, despite being explicitly warned by the court after the first incident. The false case cited in her sur-reply could not be located in any legal database. When asked to produce it, she responded that she had likely “garbled” the citation but provided no plausible alternative or correction.

Ruling/Sanction

The court declined to dismiss the action as a sanction, citing the limitations pro se litigants face in accessing reliable legal research tools. However, it granted the defendant’s motion to strike Plaintiff’s two unauthorized sur-replies and formally warned her that further violations of Rule 11 would lead to sanctions, including monetary penalties, filing restrictions, or dismissal.

AI Use

Kruglyak acknowledged he had used free generative AI tools to conduct legal research and included fabricated case citations and misrepresented holdings in his filings. He claimed ignorance of AI hallucination risk at the time of filing but stated he had since ceased such reliance and sought more reliable legal sources.

Hallucination Details

The plaintiff cited non-existent decisions and falsely attributed holdings to real ones. He did not initially disclose the use of AI but conceded it in response to the court’s show cause order. The brief at issue combined wholly fabricated cases with distorted summaries of actual ones.

Ruling/Sanction

Magistrate Judge Sargent concluded that Kruglyak had not acted in bad faith, credited his prompt admission and explanation, and noted his subsequent remedial efforts. No monetary sanctions were imposed, but the court emphasized its authority to impose such penalties if future violations occur.

Key Judicial Reasoning

The court stressed that while generative AI platforms may assist litigants, they are unreliable legal authorities prone to hallucinations. Rule 11 requires a reasonable inquiry before filing, and ignorance of AI limitations does not excuse defective legal submissions. However, leniency was warranted here due to Kruglyak’s candor and corrective action.

In a subsequent Order, the court pointed out that "This Court's opinion pointing out Buckner's citation to nonexistent case law, along with its implications, is an issue for appeal and not a valid basis for recusal. "

AI Use

Nguyen did not confirm which AI tool was used but acknowledged that AI “may have contributed.” The court inferred the use of generative AI from the pattern of hallucinated citations and accepted Nguyen’s candid acknowledgment of error, though this did not excuse the Rule 11 violation.

Hallucination Details

Fictitious citations included:

• Kraft v. Brown & Williamson Tobacco Corp., 668 F. Supp. 2d 806 (E.D. Ark. 2009)
• Young v. Johnson & Johnson, 983 F. Supp. 2d 747 (E.D. Ark. 2013)
• Carpenter v. Auto-West Inc., 553 S.W.3d 480 (Ark. 2018)
• Miller v. Hall, 360 S.W.2d 704 (Ark. 1962)

None of these cases existed in Westlaw or Lexis, and the quotes attributed to them were fabricated.

Outcome / Sanction

The court imposed a $1,000 monetary sanction on Counsel for citing non-existent case law in violation of Rule 11(b). It found her conduct unjustified, despite her apology and explanation that AI may have been involved. The court emphasized that citing fake legal authorities is an abuse of the adversary system and warrants sanctions.

AI Use

Counsel admitted using ChatGPT to draft two motions (Motion to Withdraw and Motion for Leave to Appeal), without verifying the cases or researching the AI tool’s reliability.

Hallucination Details

2 Fake cases:

• McNally v. Eyeglass World, LLC, 897 F. Supp. 2d 1067 (D. Nev. 2012) — nonexistent
• Behm v. Lockheed Martin Corp., 460 F.3d 860 (7th Cir. 2006) — nonexistent

Misused cases:

• Degen v. United States, cited for irrelevant proposition
• Dow Chemical Canada Inc. v. HRD Corp., cited despite later vacatur
• Eavenson, Auchmuty Greenwald v. Holtzman, cited despite being overruled by Third Circuit precedent

Ruling/Sanction

The Court sanctioned Counsel $2,500 payable to the court and ordered him to complete at least one hour of CLE on AI and legal ethics. The opinion emphasized that deterrence applied both specifically to Counsel and generally to the profession.

Key Judicial Reasoning

Rule 11(b)(2) mandates reasonable inquiry into all legal contentions. No AI tool displaces the attorney’s personal duty. Novelty of AI tools is not a defense.

AI Use

Counsel from Morgan & Morgan used the firm's internal AI platform (MX2.law, reportedly using ChatGPT) to add case law support to draft motions in limine in a product liability case concerning a hoverboard fire. This was reportedly his first time using AI for this purpose.

Hallucination Details

Eight out of nine case citations in the filed motions were non-existent or led to differently named cases. Another cited case number was real but belonged to a different case with a different judge. The legal standard description was also deemed "peculiar".

Ruling/Sanction

After defense counsel raised issues, the Judge issued an order to show cause. The plaintiffs' attorneys admitted the error, withdrew the motions, apologized, paid opposing counsel's fees related to the motions, and reported implementing new internal firm policies and training on AI use. Judge Rankin found Rule 11 violations. Sanctions imposed were: $3,000 fine on the drafter and revocation of his pro hac vice admission; $1,000 fine each on the signing attorneys for failing their duty of reasonable inquiry before signing.

Key Judicial Reasoning

The court acknowledged the attorneys' remedial steps and honesty but emphasized the non-delegable duty under Rule 11 to make a reasonable inquiry into the law before signing any filing. The court stressed that while AI can be a tool, attorneys remain responsible for verifying its output. The judge noted this was the "latest reminder to not blindly rely on AI platforms' citations".

AI Use

The plaintiff submitted citations that were entirely fabricated. When challenged, Saxena denied AI use and insisted the cases existed, offering no evidence. The court concluded either he fabricated the citations or relied on AI and failed to verify them.

Hallucination Details

• Spokane v. Douglass turned out to conflate unrelated decisions and misused citations from other cases
• Hummel v. State could not be found in any Nevada or national database; citation matched an unrelated Oregon case

The court found no plausible explanation for these citations other than AI generation or outright fabrication.

Ruling/Sanction

The court dismissed the case with prejudice for repeated failure to comply with Rule 8 and for the submission of fictitious citations. Though no separate sanctions motion was granted, the court's ruling incorporated the AI misuse into its reasoning and concluded that Saxena could not be trusted to proceed further in good faith.

Key Judicial Reasoning

Citing Morgan v. Cmty. Against Violence, the court reasoned that “courts do not make allowances for a plaintiff who cites to fake, nonexistent, misleading authorities.” Saxena’s refusal to acknowledge the fabrication compounded the issue. In a subsequent order, the court held that being pro se and disabled "is no excuse for submitting non-existent authority to the court in support of a brief".

In the case of Gonzalez v. Texas Taxpayers and Research Association, the court found that Plaintiff's counsel, John L. Pittman III, included fabricated citations, miscited cases, and misrepresented legal propositions in his response to a motion to dismiss. Pittman initially denied using AI but later admitted to using Lexis Nexis's AI citation generator. The court granted the defendant's motion to strike the plaintiff's response and imposed monetary sanctions on Pittman, requiring him to pay $3,852.50 in attorney's fees and $108.54 in costs to the defendant. The court deemed this an appropriate exercise of its inherent power due to the abundance of technical and substantive errors in the brief, which inhibited the defendant's ability to efficiently respond.

AI Use

The court noted “problems with several citations leading to different or non-existent cases and a quotation that did not appear in any cases cited” in defendants’ reply papers. While the court did not identify AI explicitly, it flagged the issue and indicated that repeated infractions could lead to sanctions.

Ruling/Sanction

No immediate sanction. The court granted plaintiff’s motion in part, striking thirteen of eighteen affirmative defenses. It emphasized that if citation issues persist, sanctions will follow.

Key Judicial Reasoning

Magistrate Judge Sheri Pym found the motion legally deficient on multiple grounds. In addition, she emphasized that counsel must not rely on fake or unverified authority. She cited Mata, Park, Gauthier, and others as cautionary examples of courts imposing sanctions for AI-generated hallucinations. The court reaffirmed that the use of AI does not lessen the duty to verify the existence and relevance of cited law.

AI Use

Counsel admitted using a “new legal research medium”, appears to be a generative AI system or platform capable of generating fictitious case law. Counsel did not deny using AI, but claimed the system may have been corrupted or unreliable. The amended filing removed the false authorities.

Hallucination Details

The court did not identify the specific fake cases but confirmed that “citations to non-existent cases” were included in Defendants’ original brief. Counsel’s subsequent filing corrected the record but did not explain how the citations passed into the brief in the first place.

Ruling/Sanction

Judge William Griesbach denied the motion for summary judgment on the merits, but addressed the citation misconduct separately. He cited Rule 11 and Park v. Kim (91 F.4th 610, 615 (2d Cir. 2024)) to underline the duty to verify. No formal sanctions were imposed, but counsel was explicitly warned that further use of non-existent authorities would not be tolerated.

Key Judicial Reasoning

The court emphasized that even if the submission of false citations was not malicious, it was still a serious breach of Rule 11 obligations. Legal contentions must be “warranted by existing law,” and attorneys are expected to read and confirm cited cases. The failure to do so, even if caused by AI use, is unacceptable. The court accepted counsel’s corrective effort but insisted that future violations would be sanctionable.

AI Use

Defense counsel Andrew Francisco submitted filings quoting and relying on a fabricated case (United States v. Harris, 761 F. Supp. 409 (D.D.C. 1991)) and a nonexistent quotation. Although Francisco claimed he had not used AI, the court found the fabrication bore the hallmarks of an AI hallucination and rejected his explanations as implausible.

Hallucination Details

Francisco cited and quoted from a wholly fictitious United States v. Harris case, which neither existed at the cited location nor contained the quoted material. Upon confrontation, Francisco incorrectly tried to shift the source to United States v. Broussard, but that case also did not contain the quoted text. Searches in Westlaw and Lexis confirmed the quotation existed nowhere.

Ruling/Sanction

The Court formally sanctioned Francisco for degrading the integrity of the court and violating professional responsibility rules. Although monetary sanctions were not immediately imposed, the misconduct was recorded and would be taken into account in future disciplinary proceedings if warranted.

Key Judicial Reasoning

The court emphasized that submitting fake legal authorities undermines judicial credibility, wastes opposing parties' resources, and abuses the adversarial system. Persistent refusal to candidly admit errors aggravated the misconduct. The Court explicitly cited Mata v. Avianca and other AI hallucination cases as precedent for sanctioning such behavior, finding Francisco’s case especially egregious due to repeated bad faith evasions after being given opportunities to correct the record.

AI Use

Professor Jeff Hancock, a Stanford University expert on AI and misinformation, used GPT-4o to assist in drafting an expert declaration submitted by the Minnesota Attorney General's office in defense of a state law regulating AI deepfakes in elections.

Hallucination Details

The declaration contained citations to three non-existent academic articles, apparently generated when the AI misinterpreted Hancock's notes to himself (e.g., "[cite]") as prompts to insert references. Opposing counsel identified the fake citations.

Ruling/Sanction

Professor Hancock admitted the errors resulted from unchecked AI use, explaining it deviated from his usual practice of verifying citations for academic papers, and affirmed the substance of his opinions remained valid. Judge Laura M. Provinzino found the explanation plausible but ruled the errors "shattered his credibility". The court excluded the expert declaration as unreliable, emphasizing that signing a declaration under penalty of perjury requires diligence and that false statements, innocent or not, are unacceptable.

Key Judicial Reasoning

The court found it "particularly troubling" that the expert exercised less care with a court filing than with academic work. While not faulting the use of AI itself, the court stressed the need for independent judgment and verification, stating the incident was a reminder that Rule 11's "inquiry reasonable under the circumstances" might now require attorneys to ask witnesses about their AI use and verification steps. The irony of an AI misinformation expert falling victim to AI hallucinations in a case about AI dangers was noted.

AI Use

Although O’Brien denied deliberate fabrication and described the inclusion of fake citations as a “minor clerical error” or “mix-up,” the court rejected this explanation. The opinion notes that the citations had no plausible source in other filings and that the brief exhibited structural traits of AI-generated text. The court explicitly concluded that O’Brien “generated his Reply with the assistance of a generative artificial intelligence program.”

Ruling/Sanction

The court dismissed the case with prejudice on dual grounds:

• The claims should have been raised as compulsory counterclaims in prior pending litigation and were thus procedurally barred under Rule 13(a)
• O’Brien submitted fake legal citations, failed to acknowledge the issue candidly, violated local rules, and engaged in a pattern of procedural misconduct in this and other related litigation. While monetary sanctions were not imposed, the court granted the motion to strike and ordered dismissal with prejudice as both substantive and disciplinary remedy.

Key Judicial Reasoning

Judge Melissa Damian found that the fabricated citations and O’Brien’s refusal to admit or correct them constituted bad faith. She referenced multiple prior instances where O’Brien had been warned or sanctioned for similar behavior, and emphasized that while pro se litigants may receive procedural leniency, they are not exempt from ethical or legal standards. Dismissal with prejudice was chosen as a proportionate sanction under the court’s inherent powers.

AI Use

Alim Al-Hamim, appearing pro se (self-represented), used a generative AI tool to prepare his opening brief appealing the dismissal of his claims against his landlords. He had also submitted a document with fabricated citations in the lower court.

Hallucination Details

The appellate brief contained eight fictitious case citations alongside legitimate ones. The court could not locate the cases and issued an order to show cause.

Ruling/Sanction

Al-Hamim admitted relying on AI, confirmed the citations were hallucinations, stated he failed to inspect the brief, apologized, and accepted responsibility. The court affirmed the dismissal of his claims on the merits. While finding his submission violated Colorado Appellate Rules (C.A.R. 28(a)(7)(B)), the court exercised its discretion and declined to impose sanctions.

Key Judicial Reasoning

Factors against sanctions included Al-Hamim's pro se status, his contrition, lack of prior appellate violations, the absence of published Colorado precedent on sanctions for this issue, and the fact that opposing counsel did not raise the issue or request sanctions. However, the court issued a clear and strong warning to "the bar, and self-represented litigants" that future filings containing AI-generated hallucinations "may result in sanctions". The court emphasized the need for diligence, regardless of representation status.

AI Use

The court did not specify how the hallucinated material was generated but described the bulk of appellant’s cited cases as “phantom case law.”

Hallucination Details

The court identified that the “Augmented Appendix Sections” attached to each brief consisted of numerous nonexistent Florida cases. Some real cases were cited, but quotes attributed to them were fabricated.

Ruling/Sanction

Dismissal of both consolidated appeals as a sanction. Bar on further pro se filings in the underlying probate actions without review and signature of a Florida-barred attorney. Clerk directed to reject noncompliant future filings

Key Judicial Reasoning

The Court held that Gutierrez’s submission of fictitious legal authorities and failure to respond to the show cause order constituted an abuse of process. It emphasized that pro se litigants are bound by the same rules as attorneys and referenced prior sanctions cases involving AI hallucinations.

AI Use

Plaintiff’s proposed second amended complaint included multiple fictitious legal authorities, phrased in language suggesting generative AI use (e.g., “Here are some relevant legal precedents...”). The court stated it “bears some of the hallmarks of an AI response” and noted that the citations appeared to have been “invented by artificial intelligence (‘AI’).”

Hallucination Details

The court could not locate the following cited cases:

• Ford v. District of Columbia, 70 F.3d 231 (D.C. Cir. 1995)
• Davis v. District of Columbia, 817 A.2d 1234 (D.C. 2003)
• Ward v. District of Columbia, 818 A.2d 27 (D.C. 2003)
• Reese v. District of Columbia, 37 A.3d 232 (D.C. 2012)

These were used to allege a pattern of constitutional violations by the District but were found to be fabricated.

Ruling/Sanction

The court denied Plaintiff’s motion to file a second amended complaint and dismissed the federal claims with prejudice. No formal Rule 11 sanctions were imposed, but the court emphasized the importance of verifying legal citations, citing Mata v. Avianca as precedent for how courts have responded to similar AI-related misuse.

Key Judicial Reasoning

The Court noted that while AI may be a helpful tool for pro se litigants, its use does not relieve them of the obligation to verify that every citation is real. The submission of fictitious legal authorities, even if inadvertent, is improper and may warrant sanctions. Here, the repeated failure to plead a viable claim after multiple amendments led to dismissal with prejudice.

AI Use

Monk admitted using the Claude AI tool to draft a summary judgment opposition without adequately verifying the case citations or quotations. He later claimed to have attempted post-hoc verification through Lexis AI but did not correct the errors until after a judicial show cause order.

Hallucination Details

Cited two completely nonexistent cases. Also fabricated quotations attributed to real cases, including Morales v. SimuFlite, White v. FCI USA, Burton v. Freescale, among others. Several "quotes" did not appear anywhere in the cited opinions.

Ruling/Sanction

The court imposed a $2,000 fine, ordered Monk to complete at least one hour of CLE on generative AI in legal practice, and mandated formal disclosure of the sanctions order to his client. It also permitted amendment of the defective filing but warned of the severity of the misconduct.

Key Judicial Reasoning

The court emphasized that attorneys remain personally responsible for the verification of all filings under Rule 11, regardless of technology used. Use of AI does not dilute the duty of candor. Continued silence and failure to rectify errors after opposing counsel flagged them exacerbated the misconduct.

In the November 2024 Show Cause Order, Judge Robinson noted that: "First, the briefing does not cite the forum-selection clause from the contract between the parties; instead, it cites and quotes a forum-selection clause that appears nowhere in the papers submitted by the parties. Second, Defendant’s reply brief includes a citation, Hogan v. Allstate Insurance Co., No. 19-CV-00262-JPM, 2020 WL 1882334 (D. Kan. Apr. 15, 2020), in which the court purportedly “transferred a case to the Southern District of Texas because the majority of the witnesses were located in Texas. The court found that the burden on the witnesses outweighed the convenience of litigating the case in Kansas.” As far as the Court can tell, this case does not exist. The Westlaw database number pulls up no case; the Court has found no case in CM/ECF between the parties “Hogan” and “Allstate Insurance Co.” Moreover, docket numbers in this district have at least four digits—not three—after the case-type designation, and there is no judge in this district with the initials “JPM.”"

During the show cause hearing (Transcript), Counsel apologised and pledged to reimburse the other side's costs, as well as his client's.

AI Use

Plaintiff’s counsel admitted using generative AI to draft a motion to remand without independently verifying the legal citations or the factual accuracy of quoted complaint allegations.

Hallucination Details

Cited a fabricated case (details of the specific case name not listed in the ruling). Included fabricated quotations from the complaint, suggesting nonexistent factual allegations.

Ruling/Sanction

The Court imposed a $2,500 sanction payable by December 30, 2024. Counsel was also required to notify the California State Bar of the sanction and file proof of notification and payment. The Court recognized mitigating factors (health issues, post-hoc corrective measures) but stressed the seriousness of the violations.

Key Judicial Reasoning

Rule 11 requires attorneys to conduct a reasonable inquiry into both facts and law. Use of AI does not diminish this duty. Subjective good faith is irrelevant: violations occur even without intent to deceive. AI-generated filings must be reviewed with the same rigor as traditional submissions.

The lawyer for the petitioner admitted to not reviewing the memorandum, which was prepared by a paralegal. The court deemed the Pretrial Memorandum stricken but did not impose a monetary penalty, considering the economic situation of the petitioner and the lawyer's service to a client who might otherwise be unrepresented. It was also pertinent that the law being stated was accurate (even if the citations were wrong).

AI Use

In a trust accounting proceeding, the objectant's damages expert testified that he used Microsoft Copilot (described as an AI chatbot) to cross-check his damages calculations presented in a supplemental report.

Hallucination Details

The issue wasn't fabricated citations, but the reliability and verifiability of the AI's calculation process. The expert could not recall the specific prompts used, nor could he explain Copilot's underlying sources or methodology. He claimed using AI tools was generally accepted in his field but offered no proof.

Ruling/Sanction

The court had already found the expert's analysis unreliable on other grounds, but specifically addressed the AI use. The court attempted to replicate the expert's results using Copilot itself, obtaining different outputs and eliciting warnings from Copilot about the need for expert verification before court use. The court held, potentially as an issue of first impression in that court, that counsel has an affirmative duty to disclose the use of AI in generating evidence prior to its introduction, due to AI's rapid evolution and reliability issues. AI-generated evidence would be subject to a Frye hearing (standard for admissibility of scientific evidence in NY). The expert's AI-assisted calculations were deemed inadmissible.

Key Judicial Reasoning

The court emphasized the "garbage in, garbage out" principle, stressing the need for users to understand AI inputs and processes. It stated that the mere fact AI is used does not make its output admissible; reliability must be established. The lack of transparency regarding the AI's process was a key factor in finding the evidence unreliable.

Show cause order is here. Counsel responded to Show Cause order in this document. Show cause hearing transcript is here.

The court held: "Giving Claimant the benefit of the doubt, we suspect such citations were generated by artificial intelligence rather than the result of a deliberate attempt to mislead the Court.

We strongly caution that “[c]iting nonexistent case law or misrepresenting the holdings of a case is making a false statement to a court[;] [i]t does not matter if [generative A.I.] told you so.” Kruse v. Karlen, 692 S.W.3d 43, 52 (Mo. App. E.D. 2024) (quoting Maura R. Grossman, Paul W. Grimm, & Daniel G. Brown, Is Disclosure and Certification of the Use of Generative AI Really Necessary? 107 Judicature 68, 75 (2023)). In Kruse v. Karlen, the appellant's brief contained numerous citations to fabricated, non-existent cases. Id. at 48-51. This Court dismissed the appeal and ordered the appellant to pay $10,000 in damages to the opposing party for filing a frivolous appeal. Id. at 54.

We will not dismiss Claimant's appeal and sanction her as we did the appellant in Kruse v. Karlen because this is a straightforward unemployment compensation case between a pro se litigant and an agency of the State of Missouri, wherein the State did not have to pay outside counsel to respond to the appeal. However, litigants who use generative AI to draft their briefs should not rely on our continued magnanimity."

As acknowledged by Counsel, he also used AI to generate parts of his pleadings.

While the Court initially organised show cause proceedings leading to potential sanctions, the case was eventually settled. Nevertheless, the Court stated that it "intends to report Ms. Rasmussen’s use of mis-cited and nonexistent cases in the demurrer to the State Bar", unless she objected to "this tentative ruling".

The court pointed out: "In its brief, the Credit Union points out that the cases cited by Mehlhorn do not exist and speculates that Mehlhorn used an artificial intelligence program to draft her brief-in-chief. In her reply brief, Mehlhorn does not respond to this assertion. Instead, she cites eight new cases, none of which were referenced in her brief-in-chief. It appears, however, that four of those cases are also fictitious. At a minimum, this court cannot locate those cases using the citations provided.

We strongly admonish Mehlhorn for her violations of the Rules of Appellate procedure, and particularly for her citations to what appear to be fictitious cases. Although Mehlhorn is self-represented, pro se appellants “are bound by the same rules that apply to attorneys on appeal.” See Waushara County v. Graf, 166 Wis. 2d 442, 452, 480 N.W.2d 16 (1992). We could summarily dismiss this appeal as a sanction for Mehlhorn’s multiple and egregious rule violations. See WIS. STAT. RULE 809.83(2). Nevertheless, we choose to address the merits of Mehlhorn’s arguments as best as we are able, given the deficiencies in her briefing"

AI Use

Plaintiff, opposing motions to dismiss, filed a brief containing three fake federal case citations. Defendants raised the issue in their reply, suggesting use of ChatGPT or a similar tool. Plaintiff did not deny the accusation.

Hallucination Details

Three nonexistent cases were cited. Each cited case name and number was fictitious; none of the real cases matching those citations involved remotely related issues.

Ruling/Sanction

The court issued a formal warning to Plaintiff: any future filings containing fabricated citations or quotations will result in sanctions, including striking of filings, monetary penalties, or dismissal. No sanction imposed for this first occurrence, acknowledging pro se status and likely ignorance of AI risks.

Key Judicial Reasoning

Reliance on nonexistent precedent, even by pro se litigants, is an abuse of the adversarial system. The court cited Mata v. Avianca and Park v. Kim as establishing the principle that hallucinated case citations undermine judicial integrity and waste opposing parties’ and courts' resources. Plaintiff was formally warned, not excused.

AI Use

The court does not confirm AI use but references a legal article about the dangers of ChatGPT and states: “We cannot tell from Byrd’s brief if he used ChatGPT or another artificial intelligence (AI) source to attempt to develop his legal citations.”

Ruling/Sanction

The court affirmed the trial court’s judgment, found no preserved or adequately briefed grounds for appeal, and declined to address the vague or unsupported references. No explicit sanction or costs were imposed for the apparent AI-related deficiencies.

AI Use

The plaintiff, proceeding pro se, submitted filings citing multiple nonexistent cases. The court noted patterns typical of ChatGPT hallucinations, referencing studies and prior cases involving AI errors, though the plaintiff did not admit using AI.

Hallucination Details

Several fake citations identified, including invented federal cases and misquoted Supreme Court opinions. Defendants flagged these to the court, and the court independently confirmed they were fictitious.

Ruling/Sanction

No sanctions imposed at this stage, citing special solicitude for pro se litigants. However, the court issued a formal warning: further false citations would lead to sanctions without additional leniency.

Key Judicial Reasoning

The court emphasized that even pro se parties must comply with procedural and substantive law, including truthfulness in court filings. Cited Mata v. Avianca and Park v. Kim as established examples where AI-generated hallucinations resulted in sanctions for attorneys, underscoring the seriousness of the misconduct.