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 (978 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)
David Angel Sifuentes, III v. Christian Brothers Automotive W.D. Michigan (USA) 6 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)

The court identified that Plaintiff relied on a nonexistent case citation and noted the citation had been previously flagged in the record.

Habib Miah v. Morgan Stanley & Co. International PLC, et al. S.D. New York (USA) 6 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (1)
Source: Jesse Schaefer
ECLI:NL:RBGEL:2025:9423 Gelderland (Netherlands) 6 November 2025 Lawyer Implied
Fabricated Case Law (1)
Misrepresented Case Law (1)
Court found several cited rulings non-existent or irrelevant, rejected reliance on that case law, and dismissed the appeal.
BC Taco Restaurant Group Ltd. BC Employment Standards Tribunal (Canada) 6 November 2025 Lawyer Implied
Fabricated Case Law (1)
Travis C. Mills et al. v. Rocket Mortgage LLC et al. W.D. Louisiana (USA) 6 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Misrepresented Case Law (1)
Warning
Ross Logan v. LVNV Funding et al. D. Utah (USA) 5 November 2025 Pro Se Litigant Implied Alleged AI-hallucinated case quotations Warning
Lowrey v. City of Rio Rancho D. New Mexico (USA) 5 November 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Misrepresented Case Law (4)
Warning
Source: Jesse Schaefer
Coleman & Lewis v. PNC Bank, N.A. D. Nevada (USA) 5 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (4)
Warning
STC17832-2025 Corte Suprema de Justicia (Colombia) 5 November 2025 Judge Implied
False Quotes Case Law (2)
Order quashed
Clarke v State of Queensland (Department of Education) Queensland IRC (Australia) 5 November 2025 Pro Se Litigant ChatGPT
Fabricated Case Law (1), Legal Norm (1)
Kheir v. Titan Team, The Money Source Inc., and Auction.com S.D. Texas (Bankruptcy) (USA) 4 November 2025 Lawyer Unidentified
Fabricated Case Law (3)
False Quotes Case Law (4)
Costs Order; 6 hours CLE on generative AI; provide order to client; Bar referral. 1 USD
Source: Robert Freund
Todd E. Glass v. Foley & Lardner LLP W.D. Wisconsin (USA) 4 November 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Misrepresented Case Law (1)
Warning
Borsody v. Frontier Heritage Communities D. Kansas (USA) 4 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
Alaya Coleman v. RPF-Somers Investors, LLC, et al. E.D. Wisconsin (USA) 4 November 2025 Pro Se Litigant Implied
False Quotes Case Law (1)
Xavier Jamal Smith v. Santander Consumer USA Inc. N.D. Indiana (USA) 4 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)

Rather amazingly, plaintiff asked and was granted leave to file a "Case Law Verification Index" that contained further hallucinations.

Choksi v IPS High Court (UK) 4 November 2025 Lawyer Google AI Overview
Fabricated Case Law (2)
Misrepresented Case Law (1)
Lnu, et al. v. Bondi CA California (USA) 4 November 2025 Lawyer Implied
Fabricated Case Law (2)
False Quotes Case Law (2)
Show Cause Order
12 Os 124/25i OG (Austria) 3 November 2025 Lawyer Implied
Fabricated Case Law (1)
Misrepresented Case Law (4)
I.H. v. O.K. CA Indiana (USA) 3 November 2025 Pro Se Litigant Implied
Misrepresented Case Law (1)
Warning
Wheat v. Vichie SC New York (USA) 3 November 2025 Pro Se Litigant Implied
Fabricated Case Law (2)
Warning
Isaacs v. Novartis Pharmaceuticals Corporation D. New Jersey (USA) 3 November 2025 Lawyer ChatGPT
Fabricated Case Law (2)
Court required counsel to certify completion of an AI seminar
Tan Hai Peng Micheal and another High Court (Singapore) 3 November 2025 Lawyer Unidentified
Fabricated Case Law (2)
534246-07-22 (Israel) 2 November 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Misrepresented Case Law (1)
Monetary Sanction 1000 ILS
Wertheimer v. Ryanair DAC Small Claims Court (Israel) 1 November 2025 Lawyer Implied
Fabricated Case Law (1)
Costs denied

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.

Osman Medical Centre v. Santé Québec (International Arbitration) 1 November 2025 Arbitrator Unidentified
Fabricated Case Law (1)
(Set-aside pending)

See report here.

State ex rel. Soretha Marie Eldridge v. Judge Ashley Kilbane CA Ohio (USA) 31 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)

Relator admitted her petition contained citation errors and hallucinated cases after relying on inadequate assistance; court denied leave to amend and dismissed the writs.

Source: Jesse Schaefer
Kaleb Alexander Hoosier v. Executive Centre Association, et al. D. Hawai‘i (USA) 31 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1), Legal Norm (1)
Misrepresented Legal Norm (1)
County of Los Angeles v. Neill Francis Niblett CA California (USA) 31 October 2025 Lawyer Unidentified
Fabricated Case Law (2)
Misrepresented Case Law (4)
Show Cause Order
Medical Buyers Group LLC d/b/a Integrity v. Candice Pence, et al. M.D. Georgia (USA) 31 October 2025 Lawyer Implied
Fabricated Case Law (3)
Misrepresented Case Law (1)
Cost Order and Public Admonishment 10000 USD

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

Attorney Disciplinary Board v. Richard Louis Pazdernik, Jr. Iowa Supreme Court (USA) 31 October 2025 Lawyer ChatGPT
Fabricated Case Law (1)
Misrepresented Case Law (1)
Public reprimand
In re: Tracy Johnson CA Texas (USA) 30 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
In re: Pamela Williams N.D. Georgia (Bankruptcy) (USA) 30 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)

Debtor cited a case the court could not locate; the court noted the citation appears incorrect and may be an AI "hallucination," and referenced other decisions sanctioning reliance on fabricated AI-generated cases.

Lareina A. Sauls v. Pierce County, et al. W.D. Washington (USA) 30 October 2025 Pro Se Litigant Implied
Misrepresented Case Law (1)
Warning
Nonnie Berg v. United Airlines, Inc. (1) D. Colorado (USA) 30 October 2025 Pro Se Litigant Implied
Fabricated Case Law (5), Exhibits or Submissions (1)
Warning

In an earlier Report and Reccomendations, the court found that significant portions of the plaintiff's filings copied from an AI program included citations to cases that could not be identified in Westlaw and an apparent AI-generated medical report; the court struck the filings and instructed compliance with Rule 11 and practice standards.

In re: the Marriage of Melinda Johnson v. Sabastian Johnson CA Indiana (USA) 30 October 2025 Pro Se Litigant ChatGPT
Fabricated Case Law (1)
Misrepresented Legal Norm (1)
Warning

The court observed that Mother's briefs included many cited authorities that do not exist and that one statute she cited was not on point. Mother admitted using Chat GPT to prepare pleadings. The court affirmed the trial court's orders and warned litigants to verify AI-generated citations.

Warner v. Gilbarco, Inc. E.D. Michigan (USA) 30 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Warning
Huang v. Champion Homes Sales NSW (Australia) 30 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
Misrepresented Case Law (1)

The appellant admitted using generative AI to prepare her Amended Grounds of Appeal. The Appeal Panel and respondent identified numerous incorrect or inapplicable citations and legal propositions generated by AI; the panel noted the appellant failed to verify those citations contrary to NCAT Procedural Direction 7 and treated the Amended Grounds as unreliable in parts when assessing whether questions of law were raised.

O.K. v. Southern Ontario Secondary Schools Association Human Rights Tribunal of Ontario (Canada) 30 October 2025 Lawyer Implied
Fabricated Case Law (1)
Mezu v. Mezu CA Maryland (USA) 29 October 2025 Lawyer ChatGPT
Fabricated Case Law (1)
False Quotes Case Law (1)
Misrepresented Case Law (1)
Referral to Attorney Grievance Commission
Source: Robert Freund
Joy Wilson v. KIPP Texas, Inc. N.D. Texas (USA) 29 October 2025 Lawyer ChatGPT
False Quotes Exhibits or Submissions (1)
Costs Order; 2h of CLE 1 USD
Source: Robert Freund
Robert Cole Stemkowski Goldman v. Arizona Board of Regents D. Arizona (USA) 29 October 2025 Lawyer Implied
Fabricated Case Law (1)
False Quotes Case Law (1)
Misrepresented Case Law (1)
Show Cause Order
Source: Jesse Schaefer
Ronald H. Foster v. Author Success Publishing, et al. M.D. Alabama (USA) 29 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
False Quotes Case Law (1)
Show Cause Order
Source: Jesse Schaefer
Sky Gardens Queensland BCCMC (Australia) 29 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1), Exhibits or Submissions (1)
False Quotes Case Law (1)
Misrepresented Case Law (1)
Adverse costs order for "misconceived and without substance" application 2000 AUD
Bourse de l'Immobilier Multilogements inc. c. Lanthier CS Québec (Canada) 29 October 2025 Pro Se Litigant ChatGPT
Fabricated Case Law (3)
Monetary sanction 750 CAD
Ryan Andrew Nelson v. State Farm Fire and Casualty Company S.D. Georgia (USA) 28 October 2025 Pro Se Litigant Unidentified
Fabricated Case Law (1)
In re: Loletha Hale, Esq. (Boston v. Williams) N.D. Georgia (Atlanta Division) (USA) 28 October 2025 Lawyer Implied
Fabricated Case Law (1)
Misrepresented Case Law (2)
Order to notify clients; Order to file this opinion in all new cases for five years

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

Sehra Waheed v. SM 1 MMS, LLC, et al. S.D. New York (USA) 28 October 2025 Pro Se Litigant Implied
Fabricated Case Law (1)
Stelian Gheorghe v (1) BSA Ahmad Bin Hezeem & Associates LLP (2) Jimmy Haoula DIFC Court of First Instance (UAE) 28 October 2025 Lawyer Implied
Fabricated Case Law (1)
Misrepresented Case Law (2)
Adverse costs order
Green Building Initiative, Inc. v. Stephen R. Peacock & Green Globe Limited D. Oregon (USA) 27 October 2025 Lawyer Copilot
Fabricated Case Law (2)
Show Cause Order

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.

Source: Volokh
U.S. Bank National Association v. Richmond D. Maine (USA) 27 October 2025 Pro Se Litigant Implied
Misrepresented Exhibits or Submissions (1)
Show Cause Order