AI Hallucination Cases

This database tracks legal decisions1 I.e., all documents where the use of AI, whether established or merely alleged, is addressed in more than a passing reference by the court or tribunal.

Notably, this does not cover mere allegations of hallucinations, but only cases where the court or tribunal has explicitly found (or implied) that a party relied on hallucinated content or material.

As an exception, the database also covers some judicial decisions where AI use was alleged but not confirmed. This is a judgment call on my part.
in cases where generative AI produced hallucinated content – typically fake citations, but also other types of AI-generated arguments. It does not track the (necessarily wider) universe of all fake citations or use of AI in court filings.

While seeking to be exhaustive (594 cases identified so far), it is a work in progress and will expand as new examples emerge. This database has been featured in news media, and indeed in several decisions dealing with hallucinated material.2 Examples of media coverage include:
- M. Hiltzik, AI 'hallucinations' are a growing problem for the legal profession (LA Times, 22 May 2025)
- E. Volokh, "AI Hallucination Cases," from Courts All Over the World (Volokh Conspiracy, 18 May 2025)
- J-.M. Manach, "Il génère des plaidoiries par IA, et en recense 160 ayant « halluciné » depuis 2023" (Next, 1 July 2025) - J. Koebler & J. Roscoe, "18 Lawyers Caught Using AI Explain Why They Did It (404 Media, 30 September 2025)

If you know of a case that should be included, feel free to contact me.3 (Readers may also be interested in this project regarding AI use in academic papers.)

Based on this database, I have developped an automated reference checker that also detects hallucinations: PelAIkan. Check the Reports Report icon in the database for examples, and reach out to me for a demo !

For weekly takes on cases like these, and what they mean for legal practice, subscribe to Artificial Authority.

State
Party
Nature – Category
Nature – Subcategory

Case Court / Jurisdiction Date ▼ Party Using AI AI Tool Nature of Hallucination Outcome / Sanction Monetary Penalty Details Report(s)
McCaster v. United States Court of Federal Claims (USA) 23 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Admonishment
Source: David Timm
Corey v. Kenneh SC North Dakota (USA) 22 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Affirmed sanctions from lower court
Re Sriram (aka Roy) High Court (UK) 22 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
University Mall v. Okorie et al. S.D. Mississippi (USA) 22 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
False Quotes Case Law (1)
Civil contempt 1
John Weaver v. Shasta Services W.D. Pennsylvania (USA) 22 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Guardian Piazza D'Oro LLC v. Ward Ozaeta CA California (USA) 22 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Richard M. Zelma v. Wonder Group Inc. D. New Jersey (USA) 22 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
False Quotes Case Law (2)
Sanctions deferred
In re Bittrex D. Delaware (USA) 22 October 2025 Pro Se Litigant Implied
Fabricated Case Law (3)
Misrepresented Case Law (1)
Pete v. Facebook Meta Platforms E.D. Texas (USA) 22 October 2025 Pro Se Litigant Implied
False Quotes Case Law (2)
FCA US LLC v. Stan Steele/Steele Services National Arbitration Forum (UDRP) (USA) 22 October 2025 Pro Se Litigant Implied
False Quotes Case Law (2)
Warning
Wu v. Murray CA British Columbia (Canada) 21 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (2)
Costs order took hallucinations into account
Thomas Joseph Goddard v. Sares-Regis Group, Inc., et al. N.D. California (USA) 21 October 2025 Pro Se Litigant Implied
Fabricated Exhibits or Submissions (2)
Misrepresented Exhibits or Submissions (1)
Leila Kasso v. Police Officers’ Federation of Minneapolis D. Minnesota (USA) 21 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
False Quotes Case Law (1)
Misrepresented Case Law (2)
Warning

The City argued—and the Court found—that the pro se plaintiff repeatedly cited nonexistent or inaccurately attributed caselaw likely generated by AI. The Court found these citations violated Rule 11, warned the plaintiff, and declined to award fees or impose sanctions. The court preserved the original incorrect citations in the opinion as part of the record.

Megan Cowden v. US Treasury & IRS E.D. Missouri (USA) 20 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (1)

The court was unable to locate one of the plaintiff's case citations and several quotations attributed to other cases; the court suspected portions of the filings were AI-generated and noted potential Rule 11 violations but did not impose sanctions.

Tippecanoe County Assessor v. Craig Goergen Indiana Tax Court (USA) 17 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
Artur Sargsyan v. Amazon.com Inc. W.D. Washington (USA) 17 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
Mitchell Taylor Button et al. v. John Jimison (1) W.D. Washington (USA) 17 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
False Quotes Case Law (4)
Order include signed certification
Twyla Leach Minnesota DHS et al. D. Minnesota (USA) 17 October 2025 Pro Se Litigant Implied
False Quotes Case Law (1)
Warning
Serafin v. United States Department of State, et al. E.D. Missouri (USA) 16 October 2025 Pro Se Litigant Implied
Fabricated Case Law (3)
Misrepresented Case Law (2)
Warning
X.L. v. Z.L. et al Ontario SCJ (Canada) 16 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Misrepresented Case Law (6)
No reliance on authorities submitted; Monetary Sanction 1000 CAD

Costs were awarded here.

Polinski v. USA Court of Federal Claims (USA) 15 October 2025 Pro Se Litigant Implied
Fabricated Case Law (3)
Warning

"On September 3, 2025, Plaintiff filed his response to the court’s order to file copies of the cases he cited (#7). Therein, Plaintiff avers he took “concrete remedial steps” to cure the time wasted by his use of artificial-intelligence-hallucinated case citations, including “submission of the verified opinions as exhibits” (#7 at 2). Indeed, Plaintiff’s response stresses how he“obtained authentic copies” of those cases and “attached” them as exhibits. See (id.).

Plaintiff did not attach any exhibits to his response to this court’s order. The court is convinced that those two case citations are AI-hallucinated. Plaintiff’s insistence that they exist—and that he provided copies of them to this court—is bewildering."

Nima Ghadimi v. Arizona Bank & Trust, et al. D. Arizona (USA) 15 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Warning
Charles C. Force v. Capital One, N.A., et al. M.D. Florida (USA) 15 October 2025 Pro Se Litigant Implied
Fabricated Case Law (3)
False Quotes Case Law (1)
Misrepresented Case Law (2)
Outdated Advice Overturned Case Law (1)
Filings stricken; Show Cause Order
Lugasi (Aklim Systems) v. Netivot Municipality Beersheba Magistrate's Court (Israel) 15 October 2025 Pro Se Litigant ChatGPT
Fabricated Exhibits or Submissions (1)
No reliance on hallucinated material
T.B. v K.M. King's Bench for Saskatchewan (Canada) 15 October 2025 Pro Se Litigant Implied
Fabricated Case Law (5)
Court declined to award costs to applicant; portions of the reply brief were struck; admonishment
Flores v. NICHA SC NY (USA) 15 October 2025 Pro Se Litigant Grok Case dismissed

As reported here.

Robert Allen Reed et al. v. Community Health Care et al. W.D. Washington (USA) 14 October 2025 Pro Se Litigant implied
Fabricated Case Law (5)
Warning
Hassan v ABC International Bank Employment Tribunals (UK) 13 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (3)
Misrepresented Case Law (4)
Costs Order 5881 GBP

The Claimant used AI to generate case citations in his pleadings; Tribunal found 46 inaccurate or misleading citations (9 wholly fictitious, 37 misrepresentations of real cases) and concluded the conduct was reckless and unreasonable, justifying a costs order.

David R. Pete v. United States Department of Justice, et al. E.D. Texas (USA) 10 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (2)
Magistrate Judge's recommendation adopted; in forma pauperis denied; plaintiff ordered to pay $405 filing fee within 10 days or the case will be dismissed.
Mr M Peters v Driver and Vehicle Standards Agency Employment Tribunals (Cambridge) (UK) 9 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
Misrepresented Case Law (1)
Souders v. Lazor Ohio CA (USA) 8 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Misrepresented Case Law (1)
Court rejected reliance on the cited authorities
Vivek Singha v. Metal Manufactures Fair Work Commission (Australia) 8 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (2)
Misrepresented Case Law (1)
Jose Villavicencio v. Judge Stephanie Mingo S.D. Ohio (USA) 7 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Misrepresented Case Law (1), Legal Norm (1)
Warning
Douglas Stuart Queen v. Kansas City et al. D. Kansas (USA) 7 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning

The court admonished the pro se plaintiff, expressing concern he may be relying on artificial intelligence to draft filings and cite cases without confirming accuracy, and directed him to review Fed. R. Civ. P. 11; no specific fabricated citations or false quotations were identified in the opinion.

Ren v. Area 09 BCPAAB (Canada) 7 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Misrepresented Doctrinal Work (1)
Breach of Board's Code of Conduct 910 CAD

(Monetary sanction decided in later determination, available here.)

In the Matter of Stephen C. CBCA (USA) 7 October 2025 Pro Se Litigant Unidentified
Fabricated Legal Norm (1)
Claim denied; reimbursement of moving costs denied.

Claimant cited several inapplicable regulations to support reimbursement. When directed to supply the texts, claimant admitted he had used artificial intelligence to create his submission and withdrew reliance on the cited regulations except for JTR 053710. The Board denied the claim.

Source: David Timm
Delisle v. Canadian Association of Professional Employees FPSLREB (Canada) 3 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Misrepresented Case Law (1)
NewRez LLC v. Morton SC New York (USA) 2 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
No sanction
Backhaus v. Area 01 BC Property Assessment Appeal Board (Canada) 2 October 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Warning

The appellant cited two reported decisions which the Board could not locate and concluded likely do not exist and may have been generated with AI; the Board excluded those authorities from evidence and cautioned the appellant about nondisclosure of AI per the Board's Code of Conduct.

Specter Aviation Limited v. Laprade CS Québec (Canada) 1 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
Monetary sanction for procedural misconduct 5000 CAD

Monsieur Laprade filed a contestation containing multiple citations to non-existent authorities generated with the assistance of artificial intelligence. The Court found these to be fabricated (so-called "hallucinated") citations, constituting a manquement important to the conduct of the proceeding under art. 342 C.p.c., and imposed a 5,000$ sanction.

Gavin B. Davis v. Chief Officer Gina Faubion, et al. W.D. Texas (USA) 1 October 2025 Pro Se Litigant Unidentified
Misrepresented Case Law (1), Doctrinal Work (1), Legal Norm (1)
Court accepted the R&R, dismissed the action with prejudice under 28 U.S.C. § 1915(e), and denied leave to amend.
Fernando Oliveira v Ryanair DAC Workplace Relations Commission (Ireland) 1 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (2)
Misrepresented Case Law (7)
Conduct described as abuse of process

The Adjudication Officer found the complainant's submissions contained multiple inaccurate and non‑existent legal citations. The Respondent had flagged AI‑generated drafting and numerous phantom or misquoted determinations; the Officer concluded the complainant failed to establish a prima facie case and that the submissions contained egregious and misleading citations.

Jackson v. United States DHS D. Nevada (USA) 1 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (1)
Misrepresented Case Law (1)
Warning
Tomlin v. State of New Mexico D. New Mexico (USA) 30 September 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
In re the Marriage of D.X. and S.P. CA California (USA) 30 September 2025 Pro Se Litigant Implied
Fabricated Case Law (7)
Warning

The appellate opinion and editor's note identify numerous incorrect or non-existent case citations in the appellant's filings. The court treated those citations as unreliable, found several to be fictitious or unlocatable, and declined to credit them in resolving the appeals.

In re: Todd Elliott Koger W.D. Pennsylvania (Bankruptcy) (USA) 30 September 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
One-year filing bar.

The Court observed that several authorities cited in the Kogers' pro se filings do not exist and appeared to be fabricated (noting possible use of AI), warned of Rule 9011 implications, and treated the filings as part of an abusive litigation strategy warranting dismissal and a one-year filing bar.

Mitchell Taylor Button & Dusty Button v. Juliet Doherty et al. S.D. New York (USA) 30 September 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (2)
Misrepresented Exhibits or Submissions (1)
Certification requirement for future AI-assisted filings.
Munoz v. Lopez CA California (USA) 29 September 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
Chapter Kris Jackson v. BOK Financial Corporation, et al. (2) N.D. Oklahoma (USA) 29 September 2025 Pro Se Litigant Implied
Fabricated Case Law (5)
False Quotes Case Law (1)
Show Cause Order
Jade Riley Burch v. HCA Healthcare D. Nevada (USA) 26 September 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
Misrepresented Case Law (1)
Warning