AI Hallucination Cases

" Opposing counsel, and the court, should not have to parse case citations and parentheticals to discern whether cases exist, and if so, if they stand for the propositions asserted. "

The self-represented Applicant admitted using generative AI (Google Gemini and ChatGPT) to prepare submissions. NCAT Procedural Direction 7 requires verification of citations when Gen AI is used; the Applicant did not verify citations. The Tribunal accepted the submissions into the record but placed greater weight on primary records and noted non-compliance with the verification requirement.

""101    The use of AI technology in the Courts has been the subject of judicial observations, particularly regarding legal practitioners who are subject to professional and ethical obligations and responsibilities. However, as Bell CJ observed in May v Costaras [2025] NSWCA 178 at [15], with whom Payne JA and McHugh JA agreed, in the context of considering the use of AI in the preparation of submissions, that “(a)ll litigants are under a duty not to misled the court or their opponent.” The reliance on unverified materials produced by generative AI does have the potential to misled the Court.

102    Although the termed used in relation to erroneously generated references by AI is “hallucinations”, this is a term which seeks to legitimise the use of AI. More properly, such erroneously generated references are simply fabricated, fictional, false, fake and as such could be misleading.

103    All persons appearing before the Court have a duty to verify that the case law and legislation referred to and relied on, is accurate and that such materials actually exist. The references in Ayinde at [85] and [86] and in Costaras at [14]-[15], to matters involving litigants who are acting in person who rely on AI generated material clearly supports the position that all are required to verify the submissions made to the Court. There are many publicly available legal research websites, some which are accessible without a fee. Further, and without attempting to be exhaustive, the Queensland Supreme Court library is open and available to the public.

104    The use of generative AI to prepare submissions that may include fake authorities will nearly always introduce added costs, complexity and add to the burden of other parties and to the Court: Costaras at [16] and [49]. I gratefully adopt the observation from Ayinde at [9] that “(t)here are serious implications for the administration of justice and public confidence in the justice system if artificial intelligence is misused.” The Court in Ayinde observed from [10] to [31] the existing guidance, regulatory duties of the profession, referrals and the Court’s powers. Matters which are within the Court’s own domain include in the most serious of cases contempt of Court. The observations in Ayinde at [26]-[28] regarding contempt of court are not limited to legal practitioners.

105    As the reasons above demonstrate, the circumstances of this case involved many fake authorities, fabricated quotes and false propositions. It is unhelpful for the Court to be referred to, and for parties to rely on, such matters."

"The case at bar epitomizes the concern. Inordinate judicial resources were expended on reviewing cases cited by Plaintiff that did not exist. No doubt Plaintiff’s opponent in this litigation was forced to expend similar energies. Here, too, as noted, certain cases Plaintiff cited in support of her arguments stood for the opposite result from that which Plaintiff stated in her briefs. This kind of activity not only wastes precious and limited judicial resources, but it also drives up the cost of litigation unnecessarily for those who must defend against or seek to prosecute claims on behalf of paying clients, given the underpinnings of the American Rule that attaches to most civil litigation in this country."

The debtor, Sonja Helvig DeRosa-Grund, engaged in substantial abuse of the Chapter 13 process by filing numerous frivolous motions and making false allegations against opposing counsel. The debtor repeatedly cited non-existent case law and fabricated quotes from existing cases, despite being warned about this behavior. The court dismissed the case with prejudice for one year, terminated the debtor's ECF filing privileges, and imposed additional protective measures to prevent future abuse. The court found that the debtor violated Bankruptcy Rule 9011(b) by making arguments based on non-existent case law and misquoting cases.

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. "

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.”) "