AI Hallucination Cases

Melvin Graham-Jackson, a pro se litigant, filed an appeal with false legal citations in his briefs, citing non-existent legal authorities and unrelated cases. The Court of Appeals identified this as a violation of Wisconsin's appellate rules. Despite being notified of these issues in the respondents' brief, Graham-Jackson continued to use false citations in his reply brief. The court imposed two sanctions: a $500 monetary penalty payable to the defendants to offset their legal expenses, and a requirement for Graham-Jackson to submit an affidavit in any future appeals certifying the accuracy and relevance of his legal citations.

The motion containing the fabrications had been withdrawn after the litigant was confronted, but the sanction was imposed nonetheless.

"Were Advani a lawyer, the Court would consider imposing sanctions on her. But in view of the fact that she is not a lawyer and of the dismissal of this case, the Court declines to pursue the matter further and merely warns Advani that presentation of false citations, quotations, and holdings in the future may indeed result in the imposition of sanctions."

The Father, acting pro se, relied in written submissions on numerous authorities (particularly about ASD) that HHJ Bailey identified as not genuine and apparently AI-generated; the court treated this as part of poor litigation conduct and awarded costs against him.

The civil contempt were later terminated and the accrued sanctions reduced to a money judgment. See here.

Rather ironically, plaintiff was seeking to disqualify law firm Butler Snow (of Johnson v. Dunn fame) from the case.

"Deleman admits to using generative artificial intelligence (“AI”) tools while draftinghis filings and has filed certificates of use with the Court. (Doc. 29-2; Doc. 30-2; Doc. 31-3).During the Court’s July 23, 2025, hearing, Deleman appeared to be relying entirely on AIgenerated arguments and citations. The Court directly asked Deleman whether he read thecases he cited and he claimed he did. Given that Deleman did not appear to encounter anexplanation of the term “consideration” while preparing for the hearing, the Court is skepticalof this claim. The Court reminds Deleman that false representations to the Court may warrantsanction."

"Chandra’s self-represented status does not permit him to submit information blindly. Likeevery other person who appears before the court, he has an obligation to confirm that arguments andcase law submitted to the court are supported by existing law, and a failure to do so is sanctionable."

Timothy J. Beall, a pro se litigant, admitted to using AI software to generate filings with fabricated citations. The court did not impose monetary sanctions but required Beall to include a written representation of citation accuracy in future filings. The court acknowledged the challenges faced by pro se litigants but emphasized the responsibility to ensure accurate legal citations.

The pro se litigant filed an appeal with the Supreme Court of the Commonwealth of the Northern Mariana Islands, which was dismissed with prejudice due to his repeated violations of court rules, including citing non-existent legal authorities and hallucinated cases. The court found that Zajradhara's filings were replete with fabricated citations, such as non-existent cases and misrepresented precedents. Despite being warned, plaintiff continued to submit documents with false legal references and engaged in unprofessional conduct, including personal attacks against opposing counsel and court staff. As a result, the court declared him a vexatious litigant, restricting his ability to file future litigation without express permission from the Chief Justice or Presiding Judge. No monetary penalty was imposed due to his financial circumstances.

" Further, the court is aware that relator's brief includes citations to non-existent cases. Relator is put on notice that she may face sanctions in the future for citing false caselaw. See Tex. R. App. P. 52.11(a) (“On motion of any party or on its own initiative, the court may--after notice and a reasonable opportunity to respond--impose just sanctions on a party or attorney who is not acting in good faith as indicated by any of the following... filing a petition that is clearly groundless.”) "

The Respondent, a self-represented litigant, used generative AI tools for drafting and preliminary research, leading to the citation of a non-existent case, 'Fontaine v Canada, 2004 FC 1777', in his Motion Record. The Court found this to be a fabricated citation, and the (allegedly) intended citation pointed to an irrelevant case.

The court further pointed out that the Respondent had already been caught fabricating citations in a previous proceeding. Despite acknowledging use of AI, the respondent had also failed to provide the declaration on this point required by the AI Practice Direction. The Court ordered the removal of the Motion Record from the file. Costs of $500 CAD were awarded to the Applicant.

In a later order, Respondent was designated as a vexatious litigant and enjoined from filing new cases without leave.

In the case AQ v. BW, the applicant AQ claimed damages for the non-consensual sharing of an intimate image by the respondent BW. Both parties were self-represented. The tribunal found that BW shared an intimate image of AQ without consent, violating the Intimate Images Protection Act (IIPA). BW attempted to defend their actions by citing a fabricated version of CRTA section 92, which was identified as a hallucination likely generated by artificial intelligence. Judge held:

"16. I have considered my obligation to give sufficient reasons. I do not consider that obligation to include responding to arguments concocted by artificial intelligence that have no basis in law. I accept that artificial intelligence can be a useful tool to help people find the right language to present their arguments, if used properly. However, people who blindly use artificial intelligence often end up bombarding the CRT with endless legal arguments. They cannot reasonably expect the CRT to address them all. So, while I have reviewed all the parties’ materials and considered all their arguments, I have decided against addressing many of the issues they raise. If I do not address a particular argument in this decision, it is because the argument lacks any merit, is about something plainly irrelevant, or both."

The tribunal dismissed BW's defenses as baseless and awarded AQ $5,000 in damages and an additional $1,000 for time spent due to BW's submission of irrelevant evidence. The tribunal emphasized that arguments concocted by AI without legal basis would not be addressed.

The court noted that:

"both Lehr-Guthrie's and McDonald's briefs are replete with errors in their citations to case authority, such as repeated citation errors, references to nonexistent quotes, and incorrect statements about the cases (for instance, as noted above, the two cases McDonald cited for a proposition relating to the duty of impartiality don't even reference that duty). This suggests to us that the briefs may have been drafted with the use of generative artificial intelligence (GAI). “[U]sing a GAI tool to draft a legal document can pose serious risks if the user does not thoroughly review the tool's output.” Al-Hamim v. Star Hearthstone, LLC, 2024 COA 128, ¶ 32. Self-represented litigants must be particularly careful, as they “may not understand that a GAI tool may confidently respond to a query regarding a legal topic ‘even if the answer contains errors, hallucinations, falsehoods, or biases.’ ” Id. (citation omitted).4 We advise the parties that errors caused by GAI in future filings may result in sanctions. See id. at ¶ 41. "

The court warned that future errors caused by AI could result in sanctions.

"Compounding the problem, what generative AI lacks in precision, it more than makes up for in speed. Litigants who simply file the material that AI tools generate, without carefully reviewing it first for accuracy, have the potential to swamp courts with what appear at first glance to be legal arguments built on law and precedent, but which are in fact nothing of the sort. And not only are these problems in their own right, but they also heighten the two concerns the Court highlighted above—that defendants will be forced to spend more time and incur more costs parsing through copious baseless filings to defend an action, and that Courts will waste precious time doing the same in ruling on motions and moving matters along."

(Plaintiff acknowledged use of ChatGPT in a subsequent filing)

Plaintiff was eventually designated as vexatious litigant and his case dismissed with prejudice.

Defendant Holly Nelson, appearing pro se, filed a motion to dismiss that included a fabricated case citation, Finch v. Smith, which does not exist. The court inferred that Nelson used AI to draft the motion without verifying the accuracy of the citations. The court issued an order to show cause, requiring Nelson to justify why her filing does not violate Rule 11, or alternatively, to withdraw her motion. If she fails to do so, the court intends to strike her motion entirely.

In the case of Crespo v. Tesla, Inc., the pro se plaintiff, Leonardo Crespo, submitted discovery motions containing fabricated case citations and a false quote, which were identified as potentially generated by AI. The court ordered Crespo to show cause for these submissions and admitted to using AI in his filings. The court acknowledged Crespo's candor and imposed sanctions requiring him to apologize to the defendant's counsel and pay reasonable attorney's fees incurred by the defendant in addressing the fake citations.

(In a subsequent ruling, the court averred that the reasonable fees amount was 921 USD.)