AI Hallucination Cases

In his response, Counsel acknowledged that he first researched relevant cases, and then "entered the cases into ChatGPT and requested that it highlight favorable arguments contained in the list of cases."

The Court identified multiple instances where counsel cited nonexistent cases and misquoted Cal. Civ. Code § 988(c). The Court admonished counsel, noted corrections in later briefing, and declined to credit the arguments based on the erroneous citations. No sanctions were imposed.

Morehouse replied that Warfield's filings relied on incorrect and nonexistent case citations; the Court noted that allegation but did not impose sanctions and dismissed the case for lack of personal jurisdiction.

The plaintiff, who is a lawyer , filed a claim for damages against Ryanair and included citations to several judgments to support his arguments. It was discovered that the plaintiff had used artificial intelligence to search for these judgments and/or draft the claim , and the cited cases "do not exist". The judge strongly condemned this conduct, stating it was improper and that the plaintiff's excuse for filing in haste was not acceptable. The non-existent citations were disregarded, and the court explicitly denied the plaintiff an award of costs (despite partially winning the claim) as a direct result of this conduct.

Order to show cause is here. Counsel was eventually ordered to pay 10,000 USD to opposing counsel (see here).

Party later filed for reconsideration, arguing that the judge had been biased; this failed (see here).

Lawyer later explained that he had "used Microsoft’s Copilot for its editing functions in an effort to review and improve the draft document by fixing grammar, spelling, and improving badly phrased sentences" - not for legal research.

On November 12, 2025, the court resolved the Show Cause proceedings without formal sanctions.

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

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

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

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

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

Order to show cause is here.

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

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

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

Earlier tentative order is here.

Original Show Cause Order is here.

The grounds of appeal contained at least two non-existent authorities. The judge concluded the false citations likely arose from unchecked generative-AI drafting and directed the solicitor to show cause why conduct should not be referred to the SRA.

Show Cause Order is available here.