AI Hallucination Cases

The court identified issues with the use of artificial intelligence in preparing written submissions. The submissions contained fabricated citations and fictitious quotes, which were initially filed as joint submissions by the defense and prosecution. Upon discovery, the defense counsel took responsibility, citing the use of AI without proper verification. The court allowed revised submissions to be filed, emphasizing the importance of accuracy in legal documents and the responsible use of AI. No professional sanctions or monetary penalties were imposed, but the court reiterated the need for adherence to guidelines on AI use in litigation.

The court imposed sanctions under Rule 11, requiring Mr. Owoc to complete 10 hours of community service and to certify the accuracy of legal citations in future filings if AI is used. No monetary penalty was imposed.

"Second, the protester's explanation--that it was “manual mismatches in secondary summaries” that caused the citation errors (Protester's Resp., Aug. 8, 2025, at 1)--does not meaningfully explain the number of citation errors in the protester's filings. Indeed, Oready's patently erroneous citations are far removed from mere typographical or scrivener's errors, and instead, bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification that the generated results were accurate. "

" We have the authority to sanction Wife under Florida Rule of Appellate Procedure 9.410(a) for failure to comply with Florida Rule of Appellate Procedure 9.210(c). See Gutierrez v. Gutierrez, 399 So. 3d 1185, 1188 (Fla. 3d DCA 2024). However, we decline to do so. Our decision is tempered by the fact that Wife is defending a judgment on appeal in an unrepresented capacity, Husband has not sought the imposition of sanctions, and Wife has not brought any other meritless or frivolous filings in this Court. See id. at 1187–88; Al-Hamim, 564 P.3d at 1125–26. Instead, we admonish Wife for her counterfeit brief and warn her that the Court will not regard similar infractions as mildly in the future. "

Underlying judgment (in which the hallucination had been observed) is here.

"The appearance of hallucinated citations in briefs generated from AI is no longer in its nascent stage. Regrettably, the number and regularity with which courts have been faced with hallucinations in court filings continues to rise both in this country and abroad. See Damien Charlotin, AI Hallucination Cases, (Aug. 6, 2025)https://www.damiencharlotin.com/hallucinations/ (database tracking legal decisions “in caseswhere generative AI produced hallucinated content,” evidencing 255 cases to date) (hereinafter “Charlotin Database”).

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By far, the majority of courts impose sanctions upon the offending lawyer for this sort of conduct and warnings or reprimands have been meted out in cases typically involving pro se litigants. See Charlotin Database, supra. However, there are circumstances where, in the Court’s discretion, monetary sanctions have not been imposed notwithstanding the violation of Rule 11."

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 court imposed a monetary sanction of $1,000 on the appellate counsel and ordered a report to be sent to the Illinois Attorney Registration and Disciplinary Commission (ARDC).

The appellate court found Husband's counsel made multiple misleading or incorrect citations and attributed quotations to cases that do not contain them. The court noted some citations used incorrect reporters that pointed to unrelated decisions, concluded the cited authorities did not support counsel's propositions (and in some instances contradicted them), forwarded the decision to the State Bar for possible ethical violations, and awarded costs to the prevailing party.

The appellate court dismissed the appeals due to lack of jurisdiction and ordered respondent's appellate Counsel to pay $1,000 in monetary sanctions for violating Illinois Supreme Court Rule 375 by citing multiple cases that did not stand for the propositions of law for which they were cited. The court also ordered a copy of the decision to be sent to the Illinois Attorney Registration and Disciplinary Commission.

Counsel had previously admitted to using AI to prepare briefs in another case (in Re Boy) without thoroughly reviewing the work-product, leading to similar issues. The court found it reasonable to conclude AI was used in this case as well, although not explicitly admitted by Counsel.

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

"37. The Court does not accept that there is a difference between the oral and written submissions. In fact, had there not been a request by the Plaintiff to respond, the Court would have ruled on the oral submission and such ruling could have significantly relied on the submissions of Defence Counsel. The implications are severe and serious when the Court cannot accept Counsel's assertion to be truthful and cases to be real. The risk of harm to the integrity of the judicial process is real and could bring the system into disrepute.

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40. The Court does not accept Ms. Taylor's submission that the fictitious cases were verified before layover and that they were only used in speaking points and were "not intended to form the official record." I find there is no distinction between the speaking points, oral submissions and written submission. They are all submissions advanced by Counsel intended for the Court to rely on them in the process of decision making. The purpose of which was to guide a judgment in your client's favour. The attempt to draw such a distinction is one without merit and the Court rejects same without more."

"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."

" According to father, “Welfare and Institutions Code § 350(b) states, ‘Except where otherwise provided by this code, the procedures for the trials or hearings shall be in accordance with that prescribed by law for civil cases.’ ” Section 350, subdivision (b) does not so provide, and we have been unable to verify the legal source for this quotation.3 With respect to Code of Civil Procedure, section 1013, subdivision (a), the statute addresses service by mail, facsimile and electronic service, etc., and provides, in relevant part, for an additional 10 calendar days “if either the place of mailing or the place of address is outside the State of California but within the United States.” "

Footnote 3 then reads:

" Counsel is reminded that conduct of California attorneys is governed by the State Bar Rules of Professional Conduct. In particular, rule 3.3(a)(1) places a duty on counsel not to “knowingly make a false statement of fact or law to a tribunal...,” as does Business and Professions Code section 6068, subdivision (d). This duty is violated when counsel knowingly presents statutory authority to the court that does not exist. A person's “knowledge” under this rule may be inferred from the circumstances. (Rules Prof. Conduct, rule 1.0.1(f).) Moreover, the inclusion of nonexistent legal authority may also be considered a “matter [that is] not reasonably material to the appeal's determination.” (Cal. Rules of Court, rule 8.276(a)(2).) Failure to adhere to these standards of practice and rules may result in sanctions which themselves may be mandatorily reportable to the California State Bar. (Bus. & Prof. Code, § 6068, subd. (o)(3).) "

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.

After being ordered to show cause, Counsel submitted a brief that compounded the issue.

"The Court was dismayed to see that some of the discussion/analysis provided by Mr. Chinweze appeared to be from artificial intelligence generated case summaries which was indicated by the inclusion several times of the statement that "Some case metadata and case summaries were written with the help of AI." Another indication that the paragraphs of discussion/analysis were copied from another source or were generated by AI is that several paragraphs have superscript for footnotes, but no footnotes are found on any page of the Appendix."

The court then cited this database to highlight the growing problem of hallucinations in legal cases.

Counsel was ordered to pay 1,000 USD to the Lawyers Fund for Client Protection, and he was referred to the bar authorities.

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

The court also encouraged, but did not require, Plaintiffs' counsel to complete a CLE course on LLMs and legal ethics.

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."

The court imposed a fine of 1 salário-mínimo for bad faith litigation and notified the OAB for potential professional sanctions.

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.