AI Hallucination Cases

The judge pointed out that the plaintiffs' written request included what appeared to be a direct quote from one of her own previous judgments. However, upon examination, she found that not only did this quote not exist in the cited judgment, but the judgment itself did not even address the legal question at stake.

Counsel's explanation of what happened can be found here.

" The Court has serious reason to believe that Plaintiff used artificial intelligence tools to assist in drafting her objection. While the use of such tools is not prohibited, artificial intelligence often cites to legal authorities, like Cabrera, that do not exist. Continuing to cite to non-existent cases will result in sanctions up to and including dismissal. "

AI Use

The fabricated citations originated from a ChatGPT query submitted by an unlicensed law clerk at Petitioner's law firm. Neither Counsel reviewed the petition’s contents before filing. The firm had no AI use policy in place at the time, though they implemented one after the order to show cause was issued.

Hallucination Details

Chief among the hallucinations was Royer v. Nelson, which Respondents demonstrated existed only in ChatGPT’s output and in no official database. Other cited cases were also inapposite or unverifiable. Petitioner’s counsel admitted fault and stated they were unaware AI had been used during drafting.

Ruling/Sanction

The court issued three targeted sanctions:

• Attorney fees: Respondents’ counsel are to submit an itemized bill; Counsel must pay within 10 days of receipt
• Client refund: Petitioner’s counsel must refund all fees paid by Mr. Garner in relation to the defective petition
• Charitable payment: Counsel must donate $1,000 to “and Justice for all” within 14 days and file proof of payment with the court

Key Judicial Reasoning

The panel (Per Curiam) emphasized that the conduct, while not malicious, still diverted judicial resources and imposed unnecessary burdens on the opposing party. Unlike Mata or Hayes, the attorneys in this case quickly admitted the issue and cooperated, which the court acknowledged. Nonetheless, the submission of fabricated law—especially under counsel's signature—breaches core duties of candor and verification, warranting formal sanctions. The court warned that Utah’s judiciary cannot be expected to verify every citation and must be able to trust lawyers to do so

After being ordered to show cause, plaintiff admitted having used AI for several filings.

" While in our discretion we will not impose sanctions on petitioner, who is proceeding pro se, we warn petitioner that continuing to cite nonexistent caselaw could result in the imposition of sanctions in the future. "

AI Use

First Counsel, who had not previously used AI for legal work, used an unspecified AI tool to assist with drafting a response. He failed to verify the citation before submission. Second Counsel, as local counsel, filed the response without checking the content or accuracy, even though he signed the document.

Second Counsel then said that he had initiated "procedural safeguards to prevent this error from happening again by ensuring he, and local counsel, undertake a comprehensive review of all citations and arguments filed with this and every court prior to submission to ensure their provenance can be traced to professional non-AI sources."

Hallucination Details

The hallucinated case was cited as controlling Delaware authority on privilege assignments. When challenged by Plaintiff, Defendants initially filed a bare withdrawal without explanation. Only upon court order did they disclose the AI origin and acknowledge the error. Counsel personally apologized to the court and opposing counsel.

Ruling/Sanction

Judge William Matthewman imposed a multi-part sanction:

• Attorneys’ fees and costs incurred by Plaintiff in rebutting the hallucinated citation—jointly payable by Counsel
• Required CLE on AI ethics within 30 days, with proof of completion due by June 20, 2025
• Monetary fines: $1,000 (First Counsel) and $500 (Second Counsel), payable to the Court registry

The Court emphasized that the submission of hallucinated citations—particularly when filed and signed by two attorneys—constitutes reckless disregard for procedural and ethical obligations. Though no bad faith was found, the conduct was sanctionable under Rule 11, § 1927, the Court’s inherent authority, and local professional responsibility rules.

Key Judicial Reasoning

The Court distinguished this case from more egregious incidents (O’Brien v. Flick, Thomas v. Pangburn) because the attorneys admitted their error and did not lie or attempt to cover it up. However, the delay in correction and failure to check the citation in the first place were serious enough to warrant monetary penalties and educational obligations.

Applicant sought an administrative court order to force the Israel National Academy of Sciences to let him speak at a conference on "Artificial Intelligence and Research: Uses, Prospects, Dangers". This was dismissed, with the court adding:

" I will add this: As mentioned above, the subject of the conference where the applicant wishes to speak concerns, among other things, the dangers of artificial intelligence. Indeed, one of these dangers materialized in the applicant's request: He, who is not represented, stated clearly and fairly that he used artificial intelligence for his request. An examination of the request shows that it consequently suffered from 'AI hallucinations' – it mentioned many "judgments" that never came into existence (Regarding this problem, see: HCJ 38379-12-24 Anonymous v. The Sharia Court of Appeals Jerusalem, paragraphs 13-12 (23.2.2025) (hereinafter: the Anonymous matter); HCJ 23602-01-25 The Association for the Advancement of Dog Rights v. The Minister of Agriculture, paragraphs 12-11 (28.2.2025) (hereinafter: the Association matter); and regarding the mentioned problem and the possibility of participating in the conference, see: Babylonian Talmud, Gittin 43a). Just recently, this Court warned, in no uncertain terms, that alongside the blessings of artificial intelligence, one must take excellent care against its pitfalls; 'Eat its inside, throw away its peel' (Anonymous matter, paragraph 26; Association matter, paragraph 19). The applicant did state, clearly, that he used artificial intelligence, and in light of this, he further requested that if a 'technical' error occurred under his hand – it should be seen as a good-faith mistake, not to be held against him. I cannot accept such a request. It does not cure the problems of hallucinating artificial intelligence. Those addressing this Court, whether represented or unrepresented alike, bear the burden of examining whether the precedents they refer to - which are not a 'technical' matter, but rather the beating heart of the pleadings - indeed exist, and substantiate their claims. For this reason too - the request must be dismissed"

(Translation by Gemini 2.5).

AI Use

Counsel filed a motion to dismiss appeal that cited “Greenspan v. Greenspan, 121 Hawai‘i 60, 71, 214 P.3d 557, 568 (App. 2009).” The court found that:

• No Hawai‘i case titled Greenspan v. Greenspan exists
• The citations to “121 Hawai‘i 60” and “214 P.3d 568” were in fact to other real cases (Estate of Roxas v. Marcos and Colorado Court of Appeals cases), suggesting a garbled AI-generated fabrication
• Counsel admitted delegating the brief to a per diem attorney and failing to verify the citation before filing

Ruling/Sanction

• $100 sanction imposed on counsel personally
• Payment to be made to the Supreme Court Clerk of Hawai‘i within seven days
• DiPasquale ordered to file a declaration attesting to payment.

The amount reflects counsel’s candor and corrective measures, but the court noted that federal courts have imposed higher sanctions in similar cases.

AI Use

The plaintiff, proceeding pro se, cited “Darling v. Linde, Inc., No. 21-cv-01258, 2023 WL 2320117 (D. Or. Feb. 28, 2023)” in briefing. The court stated it could not locate the case in any major legal database or via internet search and noted this could trigger Rule 11 sanctions if not based on a reasonable inquiry. The ruling cited Saxena v. Martinez-Hernandez as a cautionary example involving AI hallucinations, suggesting the court suspected similar conduct here.

Counsel later explained how the motion came to be: see here.

AI Use

In a filing related to a third-party notice, the defendant cited a judgment that did not exist. The judge clarified that this was not simply a mistaken citation or party confusion, but rather a reference to an entirely fictional judgment. The court explicitly stated: “It is not clear how such an error occurs, except through the use of artificial intelligence.”

Ruling/Sanction

The court permitted the defendant to proceed with the third-party notice but ordered partial costs (₪1,200) to be paid to the plaintiff due to procedural irregularities. The judge demanded a formal explanation of how the fictitious citation was introduced, in order to prevent recurrence

Key Judicial Reasoning

While the procedural error did not warrant barring the defendant’s claim against a third party, the court emphasized that referencing a fictional legal source is a serious issue requiring scrutiny. The opinion signals a growing judicial intolerance for unverified AI-assisted legal drafting in Israeli courts.

AI Use

A paralegal used public search tools and unspecified “AI-based research assistants” to generate legal citations. The resulting hallucinated cases were passed to Counsel, who filed them without verification. Four out of eight cited cases were found to be fictitious:

• London v. Polish Slavic Fed. Credit Union, No. 19-CV-6645
• Rosario v. 2022 E. Tremont Hous. Dev. Fund Corp., No. 21-CV-9010
• Paniagua v. El Gallo No. 3 Corp., No. 22-CV-7073
• Luna v. Gon Way Constr., Inc., No. 20-CV-893

Ruling/Sanction

The court imposed a $1,000 sanction against Counsel and her firm. Counsel was ordered to serve the sanction order on her client and file proof of service. The court declined harsher penalties, crediting her swift admission, apology, and internal reforms.

Key Judicial Reasoning

The court found subjective bad faith due to the complete absence of verification. It cited a range of other AI-related sanction decisions, underscoring that even outsourcing to a “diligent and trusted” paralegal is not a defense when due diligence is absent.

AI Use

Bandla denied using AI, claiming instead to have relied on Google searches to locate “supportive” case law. He admitted that he did not verify any of the citations and never checked them against official sources. The court found this unacceptable, particularly from someone formerly admitted as a solicitor.

Hallucination Details

Bandla’s submissions cited at least 27 cases which the Solicitors Regulation Authority (SRA) could not locate.

Bandla maintained summaries and quotations from these cases in formal submissions. When pressed in court, he admitted having never read the judgments, let alone verified their existence.

Ruling/Sanction

The High Court refused the application for an extension of time, finding Bandla’s explanations inconsistent and unreliable. The court independently struck out the appeal on grounds of abuse of process due to the submission of fake authority. It imposed indemnity costs of £24,727.20. The judge emphasized that even after being alerted to the fictitious nature of the cases, Bandla neither withdrew nor corrected them.

Key Judicial Reasoning

The court found Bandla’s conduct deeply troubling, noting his previous experience as a solicitor and his professed commitment to legal standards. It held that the deliberate or grossly negligent inclusion of fake case law—especially in an attempt to challenge a disciplinary disbarment—was an abuse requiring strong institutional response.

The second respondent, Carly Dakota Wise, a self-represented litigant, filed an application for the recusal of a tribunal member, alleging bias and procedural unfairness. The application was based on several grounds, including fabricated legal citations - despite Ms. Wise having been warned in interlocutory proceedings to check the authorities she relied on. The court cited the local Guidelines for the Use of Generative Artificial Intelligence (AI) Guidelines for Responsible Use by Non-Lawyers, available here, to stress that self-represented litigants need to check the accuracy of their pleadings.

AI Use

The petition’s pages were marked “Criado com MobiOffice.” The STF verified that MobiOffice includes a built-in AI writing assistant. Combined with the inclusion of fictitious citations, this led the Court to conclude that AI had been used and not reviewed. The judge characterized this as reckless conduct.

Hallucination Details

• Claimed violations of STF precedents including RE 464.867/SP and RE 226.855/RS, which were either inapplicable or misrepresented
• Claimed Súmula Vinculante 6 said something entirely false (its actual content concerns military service remuneration)
• Cited judgments ARE 1.218.084 AgR and RE 328.111/DF as relevant when they were either misquoted or irrelevant
• Court concluded these references were invented or misrepresented, “false statements intended to mislead”

Ruling/Sanction

• Rejected the complaint as manifestly inadmissible
• Found that counsel likely used AI and submitted the petition without review
• Ordered notification to both the national and Bahia sections of the OAB
• Declared the petitioner litigated in bad faith under Article 80, V, of the Brazilian Civil Procedure Code
• Imposed a procedural penalty of double the initial court costs
• Ordered referral to dívida ativa (federal collections) if not paid.

AI Use

The court found that several of the cases cited by the plaintiff in her briefing opposing Officer Hill’s qualified immunity defense did not exist. Although Newbern suggested the citations may have been innocent mistakes, she did not challenge the finding of fabrication. No AI tool was admitted or named, but the structure and specificity of the invented cases strongly suggest generative AI use.

Hallucination Details

The fabricated authorities were not background references, but “key authorities” cited to establish that Hill’s alleged conduct violated clearly established law. The court observed that the fake cases initially appeared to be unusually on-point compared to the rest of plaintiff’s citations, which raised suspicion. Upon scrutiny, it confirmed they did not exist.

Ruling/Sanction

The court dismissed the federal claims against Officer Hill as a partial sanction for plaintiff’s fabrication of legal authority and failure to meet the burden under qualified immunity. However, it declined to dismiss the entire case, citing the interest of the minor child involved and the relevance of potential state law claims. It permitted discovery to proceed on those claims to determine whether Officer Hill acted with malice or engaged in other conduct falling outside the scope of Mississippi Tort Claims Act immunity.

Key Judicial Reasoning

The court found that plaintiff’s citation of fictitious cases undermined her effort to meet the demanding “clearly established” standard. It rejected her claim that the fabrication was an innocent mistake and viewed it in light of her broader litigation conduct, which included excessive filings and disregard for procedural limits.

AI Use

Counsel explained that the hallucinated citations were included in a draft intended for personal legal research and learning, which was mistakenly filed with the court. This constituted an implicit admission that generative AI tools were involved.

Ruling/Sanction

While Judge Itay Katz did not impose personal costs, he referred the matter to the Legal Department of the Judicial Authority to determine whether further steps—including referral to the Israel Bar Association Ethics Committee—should be taken. The court emphasized this was done as a gesture of leniency with the hope that such behavior will not recur.

Key Judicial Reasoning

The court referred to several other recent Israeli cases to underscore the growing recognition of AI hallucination risk in legal practice. It reiterated the requirement for attorneys to meticulously verify any citation before submission and warned that future similar instances may not receive such lenient treatment.

AI Use

Dr. Wright, after beginning to represent himself, repeatedly used AI engines (such as ChatGPT or similar) to generate legal documents. These documents were characterized by the court as "highly verbose and repetitious" and full of "legal nonsense". This use of AI contributed to filings containing numerous false references to authority and misrepresentations of existing law.

Hallucination Details

While the core issue in Dr. Wright's litigation was his fundamental dishonesty (claiming to be Satoshi Nakamoto based on "lies and ... elaborately forged documents" ), the use of AI introduced specific problems. His appeal documents, bearing signs of AI creation, contained "numerous false references to authority". His later submissions also involved "citation of non-existent authorities". This AI-driven production of flawed legal arguments formed part of his broader pattern of disrespect for court rules and process.

Ruling/Sanction

Mr Justice Mellor granted a General Civil Restraint Order (GCRO) against Dr. Wright for a three-year period. He found that an Extended CRO (ECRO) would be insufficient given the scope and persistence of Dr. Wright's abusive litigation. The court also referred Dr. Wright's conduct to the Attorney General for consideration of a civil proceedings order under s.42 of the Senior Courts Act 1981. Dr. Wright was ordered to pay the applicants' costs for the CRO application, summarily assessed at £100,000.

Key Judicial Reasoning

The court found "overwhelming" evidence that Dr. Wright had persistently brought claims that were Totally Without Merit (TWM), numbering far more than the required threshold. This conduct involved extensive lies and forgeries across multiple jurisdictions and targeted individuals who often lacked the resources to defend themselves. The judge concluded there was a "very significant risk" that Dr. Wright would continue this abusive conduct unless restrained. The court noted his consistent contempt for court rules and processes, including his perjury, forgery, breach of orders, and flawed submissions (including those using AI). A GCRO was deemed just and proportionate to protect both potential future litigants and the finite resources of the court system

The STF relator found that the petition relied on decisions that could not be located and contained false statements about the content of Súmula Vinculante n.º 6 and other precedents. The petition bore a 'Criado com MobiOffice' watermark and the relator concluded the author likely used an AI writing assistant without review. The complaint was denied, bad faith was declared and procedural costs were doubled; OAB was notified.

(Grievance Committee Report available here.)

AI Use

Neusom told the grievance committee that he “may have used artificial intelligence” in preparing filings, and that any hallucinated cases were not deliberately fabricated but may have come from AI tools. The filings in question included a notice of removal and a motion for summary judgment. The judge later noted a pattern of citations inconsistent with established case law and unsupported by known databases.

Hallucination Details

Citations included cases that either did not exist or were grossly mischaracterized. Notably:

• Southern Specialties, Inc. v. Pulido Produce, Inc. – no such case found in Westlaw, Lexis, or PACER
• Trilogy Communications v. Times Fiber – cited in support of breach of contract when it was a patent matter involving no such principles

Neusom failed to produce the full texts of the cited cases when requested and instead filed a 721-page exhibit in violation of court orders.

Ruling/Sanction

The court adopted the grievance committee’s recommendation and imposed a one-year suspension. Neusom is prohibited from accepting new federal cases in the Middle District of Florida during the suspension and must:

• Notify existing clients and the court of his suspension
• File a compliance affidavit within 30 days
• Complete appropriate CLE and counseling programs
• Remain in good standing with the Florida Bar
• Apply for reinstatement only after certifying compliance

Key Judicial Reasoning

The court found that Neusom violated Rules 4-1.3, 4-3.3(a)(3), 4-3.4(c), and 4-8.4(c) of the Florida Rules of Professional Conduct. His failure to verify AI-generated content, compounded by noncompliance with orders and false statements to opposing counsel, demonstrated a pattern of recklessness and dishonesty. The court emphasized that federal proceedings require a high standard of diligence and that invoking AI cannot excuse failure to meet professional obligations.

AI Use

In opposing the return of a seized mobile phone, the prosecution cited a non-existent statutory provision allegedly defining what qualifies as an “institutional computer.” The judge identified the law as fictional and attributed its creation to generative AI, noting that it does not appear in any legal database or government source. The court referred to this as a product “created by artificial intelligence.”

Hallucination Details

The prosecution cited a statute regarding institutional computer definitions which, upon investigation, did not exist in Israeli law. The judge conducted internet and database searches to confirm its nonexistence. The judge criticized the error, remarking: “If I thought I had seen everything in 30 years on the bench, I was mistaken”

Ruling/Sanction

The judge declined to sanction the prosecution but strongly rebuked the conduct, calling it embarrassing and improper.

Key Judicial Reasoning

The judge stressed that citing phantom laws undermines public confidence and judicial efficiency. Even absent malice, reliance on fictitious AI-generated legal references is unacceptable. The judgment did not penalize the prosecution but underscored the need for due diligence and warned of reputational damage.

AI Use

GAO requested clarification after identifying case citation irregularities. The protester confirmed that their representative was not a licensed attorney and had relied on a combination of public tools, AI-based platforms, and secondary summaries, which produced fabricated or misattributed citations.

Hallucination Details

Examples included:

• GAO B-numbers with no corresponding decision
• CPD citations that did not match the referenced holding
• Alleged direct quotations not found in any GAO decision

The fabrications mirrored patterns typical of AI hallucinations.

Ruling/Sanction

Although the protest was dismissed on academic grounds, GAO addressed the citation misconduct. It did not impose sanctions in this case but warned that future submission of non-existent authority could lead to formal disciplinary action—including dismissal, cost orders, and bar referrals (in the case of attorneys).

AI Use

Counsel used CoCounsel, Westlaw’s AI tools, and Google Gemini to generate a legal outline for a discovery-related supplemental brief. The outline contained hallucinated citations and quotations, which were incorporated into the filed brief by colleagues at both Ellis George and K&L Gates. No one verified the content before filing. After the Special Master flagged two issues, counsel refiled a revised brief—but it still included six AI-generated hallucinations and did not disclose AI use until ordered to respond.

Hallucination Details

At least two cases did not exist at all, including a fabricated quotation attributed to Booth v. Allstate Ins. Co., 198 Cal.App.3d 1357 (1989). Misquoted or fabricated quotes attributed to National Steel Products Co. v. Superior Court, 164 Cal.App.3d 476 (1985). Several additional misquotes and garbled citations across three submitted versions of the brief. Revised versions attempted to silently “fix” errors without disclosing their origin in AI output.

Ruling/Sanction

The Special Master (Judge Wilner) struck all versions of Plaintiff’s supplemental brief, denied the requested discovery relief, and imposed:

• $26,100 in fees to reimburse Defendant for Special Master costs
• $5,000 in additional attorney’s fees to Defendant
• Total monetary sanction: $31,100, payable jointly and severally by Ellis George LLP and K&L Gates LLP
• No sanctions against individual attorneys due to candid admissions and remedial action, but strong warning issued

Key Judicial Reasoning

The submission and re-submission of AI-generated material without verification, especially after warning signs were raised, was deemed reckless and improper. The court emphasized that undisclosed AI use that results in fabricated law undermines judicial integrity. While individual attorneys were spared, the firms were sanctioned for systemic failure in verification and supervision. The Special Master underscored that the materials nearly made it into a judicial order, calling that prospect “scary” and demanding “strong deterrence.”

AI Use

The court observed that “some of the cases that plaintiff cites… do not exist,” and noted it had “tried, in vain,” to find them. While no explicit AI use is admitted by the plaintiff, the pattern and specificity of the fabricated citations are characteristic of LLM-generated hallucinations.

Ruling/Sanction

The court dismissed all five causes of action—including negligence, tortious interference, aiding and abetting fraud, declaratory judgment, and breach of implied covenant of good faith and fair dealing—as either untimely or duplicative/deficient on the merits. It declined to impose sanctions but explicitly invoked Dowlah v. Professional Staff Congress, 227 AD3d 609 (1st Dept. 2024), and Will of Samuel, 82 Misc 3d 616 (Sur. Ct. 2024), to warn plaintiff that any future citation of fictitious cases would result in sanctions.

Key Judicial Reasoning

Justice Jamieson noted that while the court is “sensitive to plaintiff's pro se status,” that does not excuse disregard of procedural rules or the submission of fictitious citations. The court emphasized that its prior decision in related litigation in 2022 undermined plaintiff’s tolling claims, and that Executive Order extensions during the COVID-19 pandemic did not rescue otherwise-expired claims. The hallucinated citations failed to salvage plaintiff’s fraud and tolling theories, and their use was treated as an aggravating—though not yet sanctionable—factor.

"For that principal [sic] [X] cites a case, Gunn v. McKinney, 259 F.3d 824, 829 (7th Cir. 2001), which neither defense counsel nor the Court has been able to locate. The Court reminds [X] that Federal Rule of Civil Procedure 11 applies to pro se litigants, and sanctions may result from such conduct, especially if the citation to Gunn was not merely a typographical or citation error but instead referred to a non-existent case. By presenting a pleading, written motion, or other paper to the Court, an unrepresented party acknowledges they will be held responsible for its contents. See Fed. R. Civ. P. 11(b)."

Court held that: "The use of fictitious quotes or cases in filings may subject a party, including a pro se party, to sanctions pursuant to Federal Rule of Civil Procedure 11 as “pro se litigants are subject to Rule 11 just as attorneys are.”

In their Response to the Order to show Cause, Counsel specified that they used Lexis+AI, and stressed that "LexisNexis itself has publicly emphasized the reliability of its Lexis+ AI platform, marketing it as providing “hallucination-free legal citations” specifically to avoid citation errors."
Case was eventually jointly dismissed.

The landlord sought to repossess a rental property, claiming the lease renewal was suspended based on a misinterpretation of Quebec's civil code articles. He used ChatGPT to translate these articles, which resulted in a completely different meaning. The Tribunal found the repossession request invalid as it was based on a date prior to the lease's end. The Tribunal rejected the claim of abuse, accepting the landlord's sincere belief in his misinterpretation, influenced by AI translation, and noted his language barrier and residence in Mexico. The Tribunal advised the landlord to seek reliable legal advice in the future.

AI Use

The court stated that “Moales may have used artificial intelligence in drafting his submissions,” citing widespread concerns over AI hallucination. It noted that several citations in his complaint and show-cause response were plainly incorrect or irrelevant. While Moales did not admit AI use, the court cited Strong v. Rushmore Loan Mgmt. Servs., 2025 WL 100904 (D. Neb.) and Mata v. Avianca to contextualize its concern.

Hallucination Details

Cited Ernst & Ernst v. Hochfelder, 425 U.S. 185 (1976), and S.E.C. v. W.J. Howey Co., 328 U.S. 293 (1946) as supporting the existence of a federal common law fiduciary duty—an inaccurate legal proposition. The court characterized such misuses as “the norm rather than the exception” in Moales’s submissions. It stopped short of identifying all misused authorities but made clear that the inaccuracies were pervasive.

Ruling/Sanction

The complaint was dismissed for lack of subject matter jurisdiction under Rule 12(h)(3). Moales was permitted to file an amended complaint by May 28, 2025, but was warned that future filings must be factually and legally accurate. The court declined to reach the venue issue or impose immediate sanctions but warned Moales that misrepresentation of law may violate Rule 11.

Key Judicial Reasoning

The court found no basis for federal question jurisdiction and rejected Moales’s reliance on the Declaratory Judgment Act, constructive trust theories, and a nonexistent “federal common law of securities.” It also held that Moales failed to plausibly allege the amount in controversy necessary for diversity jurisdiction.

AI Use

Counsel denied using AI directly and attributed the hallucinations to “Google and Google Scholar” searches by a junior research assistant. However, the court found the citation pattern highly characteristic of generative AI hallucinations, including plausible-sounding but non-existent authority names and improper formatting. Counsel acknowledged a lack of adequate supervision and admitted that the cited authorities were never verified nor included in the bundle.

Hallucination Details

Seven cited authorities were found to be fictitious or mischaracterized, including:

• BWIA v. Ramnarine (TT Industrial Court, 2005)
• National Petroleum Marketing Co. v. Brewster (TT 2007)
• Horner v. KMW [2000] IRLR 814
• Jones v. Manchester Corporation [1952] 2 QB 852 (used for unrelated point)
• London School of Economics v. Dr Don [2016] EAT
• Ishmael v. NIPDEC (TT, 2014)
• BWIA v. Hollis (TT, 2001)

These were used to support the implied obligation to repay employer-sponsored training, the core issue of the case. None were available in legal databases or official archives, and no hard copies were ever submitted.

Ruling/Sanction

While the court awarded judgment for the Claimant on the breach of contract claim, it found the citation misconduct egregious and referred the matter to the Disciplinary Committee of the Law Association. The Court noted that hallucinated citations undermine judicial integrity and must be proactively prevented.

Key Judicial Reasoning

Justice Westmin James emphasized that lawyers must not submit unverifiable or fictitious authority, whether generated by AI or not. He underscored that the legal system depends on the accuracy of submissions, and that even unintentional use of hallucinated material violates the duty of candour and may constitute professional misconduct.

AI Use

The plaintiff’s attorney denied deliberate use of generative AI, claiming the wrong file numbers were inserted by mistake. The court rejected this explanation, finding the hallucinated decisions did not exist in any legal archive and could not plausibly arise from mere misnumbering. The court accepted the defendant’s assertion that the fabricated citations originated from generative AI.

Hallucination Details

Out of five rulings cited in the petition, three were not found in any legal database. Two additional cases were filed after the hearing, but neither matched the original citations or contained the propositions advanced in the pleading. The court found the overall drafting pattern aligned with generative AI hallucination phenomena.

Ruling/Sanction

Judge Merav Eliyahu dismissed the petition and imposed personal costs of ₪1,500 against Plaintiff’s counsel (payable to the state) and ₪3,500 (payable to the opposing party). She cited Supreme Court precedent and ethical commentary emphasizing the risks of hallucinated legal drafting. She emphasized that lawyers must not rely blindly on AI tools and must always verify the authenticity of legal authorities cited in pleadings.

Key Judicial Reasoning

The judge found that legal pleadings are the “foundational documents of judicial proceedings” and must be “accurate, reliable, and competently drafted.” Submitting fictitious judgments constitutes not only a procedural abuse but an ethical breach. Even absent bad faith, failure to verify AI-generated legal content breaches a lawyer’s core obligations.

"Ms. Simpson referred to a non-existent CRT case to support a patently incorrect legal position. She also referred to three Supreme Court of Canada cases that do not exist. Her submissions go on to explain in detail what legal principles those non-existent cases stand for. Despite these deficiencies, the submissions are written in a convincingly legal tone. Simply put, they read like a lawyer wrote them even though the underlying legal analysis is often wrong. These are all common features of submissions generated by artificial intelligence." [...]

"25. I agree with Hung Long that there are two extraordinary circumstances here that justify compensation for its time. The first is Ms. Simpson’s use of artificial intelligence. It takes little time to have a large language model create lengthy submissions with many case citations. It takes considerably more effort for the other party to wade through those submissions to determine which cases are real, and for those that are, whether they actually say what Ms. Simpson purported they did. Hung Long’s owner clearly struggled to understand Ms. Simpson’s submissions, and his legal research to try to understand them was an utter waste of his time. I reiterate my point above that Ms. Simpson’s submissions cited a non-existent case in support of a legal position that is the precise opposite of the existing law. This underscores the impact on Hung Long. How can a self-represented party respond to a seemingly convincing legal argument that is based on a case it is impossible to find?

26. I am mindful that Ms. Simpson is not a lawyer and that legal research is challenging. That said, she is responsible for the information she provides the CRT. I find it manifestly unfair that the burden of Ms. Simpson’s use of artificial intelligence should fall to Hung Long’s owner, who tried his best to understand submissions that were not capable of being understood. While I accept that Ms. Simpson did not knowingly provide fake cases or misleading submissions, she was reckless about their accuracy."

AI Use

Counsel used ChatOn to rewrite a reply brief with case law, under time pressure, without verifying the outputs. The five cases did not exist; citations were entirely fictional. Counsel later admitted this in a sworn declaration and at hearing, describing her actions as a lapse caused by workload and inexperience with AI.

Hallucination Details

Fabricated cases included:

• Klein v. E.I. Du Pont de Nemours & Co., 406 F.2d 1004 (cited case does not exist)
• Gordon v. N.Y. Cent. R.R. Co., 202 F. Supp. 2d 290
• Mitchell v. JCG Industries, 2010 WL 11627832
• Hollander v. Sweeney, 2005 WL 19904045
• Davis v. S. Farm Bureau Cas. Ins. Co., 2019 WL 3452601

None of these cases matched any legal source. Counsel filed them as part of a sworn statement under penalty of perjury.

Ruling/Sanction

The court imposed a $1,000 sanction payable to the Clerk; ordered the counsel to serve the order on her client and file proof of service. The court acknowledged her sincere remorse and remedial CLE activity, but emphasized the seriousness of submitting hallucinated cases under oath. Sanctions were tailored for deterrence, not punishment.

Key Judicial Reasoning

Quoting Park v. Kim and Mata v. Avianca, the court held that submitting legal claims based on nonexistent authorities without checking them constitutes subjective bad faith. Signing a sworn filing without knowledge of its truth is independently sanctionable. Time pressure is not a defense. Lawyers cannot outsource core duties to generative AI and disclaim responsibility for the results.

AI Use

Plaintiff submitted a motion to disqualify opposing counsel that cited multiple non-existent cases. She offered no clarification about how the citations were obtained or whether she had attempted to verify them. The court noted this failure and declined to excuse the misconduct, though it stopped short of attributing it directly to AI tools.

Hallucination Details

The court reviewed Plaintiff’s motion and found that some of the cited cases did not exist. Despite being ordered to show cause, Plaintiff responded only with general statements about her good faith and complaints about perceived procedural unfairness, without addressing the origin or verification of the fake cases.

Ruling/Sanction

The court dismissed the case for lack of subject matter jurisdiction and independently dismissed it as a sanction for bad-faith litigation under Rule 11. It found Plaintiff’s conduct—submitting fictitious legal authorities and refusing to take responsibility for them—warranted dismissal, even if monetary sanctions were not appropriate. The court cited Mata v. Avianca, Morgan v. Community Against Violence, and O’Brien v. Flick as relevant precedents affirming the sanctionability of hallucinated case law.

Key Judicial Reasoning

Judge Hall held that Plaintiff’s conduct went beyond excusable error. Her submission of fabricated cases, refusal to explain their origin, and attempts to shift blame to perceived procedural grievances demonstrated bad faith. The court concluded that dismissal—though duplicative of the jurisdictional ground—was warranted as a standalone sanction to deter future abuse by similarly situated litigants.

Although no immediate sanctions were imposed, Magistrate Judge Ho explicitly warned Plaintiff that future misconduct of this nature may violate Rule 11 and lead to consequences.

AI Use

Mr. Ferris admitted at the April 8, 2025 hearing that he used ChatGPT to generate the legal content of his filings and even the statement he read aloud in court. The filings included at least seven entirely fictitious case citations. The court noted the imbalance: it takes a click to generate AI content but substantial time and labor for courts and opposing counsel to uncover the fabrications.

Hallucination Details

The hallucinated cases included federal circuit and district court decisions, complete with plausible citations and jurisdictional diversity, crafted to lend credibility to Plaintiff’s intellectual property and employment-related claims. These false authorities were submitted both in the complaint and in opposition to Amazon’s motion to dismiss.

Ruling/Sanction

The court found a Rule 11 violation and, while initially inclined to dismiss the case outright, chose instead to impose a compensatory monetary sanction. Amazon is entitled to submit a detailed affidavit of costs directly attributable to rebutting the false citations. The final monetary amount will be set in a subsequent order.

Key Judicial Reasoning

Judge Michael P. Mills condemned the misuse of generative AI as a serious threat to judicial integrity. Quoting Kafka (“The lie made into the rule of the world”), the court lamented the rise of “a post-truth world” and framed Ferris as an “avatar” of that dynamic. Nevertheless, it opted for the least severe sanction consistent with deterrence and fairness: compensatory costs under Rule 11.

After explaining what happened (document) counsel opted to non-suit all remaining claims, which means that the court never ruled on the show cause proceedings.