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.
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 (13 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 
in the database for examples, and reach out to me if for a demo !
For weekly takes on cases like these, and what they mean for legal practice, subscribe to Artificial Authority.
| Case | Court / Jurisdiction | Date ▼ | Party Using AI | AI Tool ⓘ | Nature of Hallucination | Outcome / Sanction | Monetary Penalty | Details | Reports |
|---|---|---|---|---|---|---|---|---|---|
| Russel Williams Home Services LLC v. Minleon International (USA) Limited LLC, et al. | M.D. Pennsylvania (USA) | 17 December 2025 | Lawyer | Implied |
False Quotes
Case Law
(2)
|
Order to Show Cause | — | — | |
| Robert W. Williams, Sr. v. Assistant District Attorney John R. Canavan, et al. | M.D. Pennsylvania (USA) | 15 December 2025 | Pro Se Litigant | Unidentified |
False Quotes
Case Law
(1)
Misrepresented
Case Law
(1)
|
Warning | — | — | |
| South Side Area School District et. al v. Pennsylvania Human Relations Commission, | Pennsylvania CC (USA) | 10 December 2025 | Lawyer | Implied |
False Quotes
Case Law
(1)
Misrepresented
Case Law
(1)
|
— | — | ||
|
See story here. |
|||||||||
| Associated Builders and Contractors v. Bucks County Community College | CC Pennsylvania (USA) | 5 December 2025 | Lawyer | Unidentified |
Fabricated
Case Law
(1)
|
Brief struck and ignored | — | — | |
| Mullins v. Duquesne University of the Holy Spirit | W.D. Pennsylvania (USA) | 5 December 2025 | Pro Se Litigant | Implied |
False Quotes
Case Law
(3)
|
Reply struck; Order to disclose AI use | — |
Plaintiff's Reply
|
|
| United States v. Brian Boehm | M.D. Pennsylvania (USA) | 3 December 2025 | Pro Se Litigant | Implied |
False Quotes
Case Law
(2)
Misrepresented
Case Law
(1)
|
Ordered disclosure of AI use and affidavit certifying accuracy of citations for future filings | — | — | |
|
"12) The Al tool possibly used was sophisticated enough to include pinpoint citations to precedential Third Circuit authority. |
|||||||||
| Saber v. Navy Federal Credit Union | SC Pennsylvania (USA) | 28 October 2025 | Pro Se Litigant | Implied |
Fabricated
Case Law
(2)
|
Warning | — | — | |
| John Weaver v. Shasta Services | W.D. Pennsylvania (USA) | 22 October 2025 | Pro Se Litigant | Implied |
Fabricated
Case Law
(2)
|
— | — | ||
| Thomas Dexter Jakes v. Duane Youngblood | W.D. Pennsylvania (USA) | 6 October 2025 | Lawyer | Implied |
False Quotes
Case Law
(8),
Exhibits or Submissions
(1)
Misrepresented
Case Law
(1)
|
Monetary Sanction; Pro Hac Vice status revoked | 5000 USD | — | |
|
Original Show Cause Order is here. |
|||||||||
| Source: Volokh | |||||||||
| 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. |
|||||||||
| Lonnie Allbaugh v. University of Scranton | M.D. Pennsylvania (USA) | 28 August 2025 | Pro Se Litigant | Unidentified |
Fabricated
Case Law
(2)
|
Monetary sanction; complaint dismissed without prejudice; leave to amend granted. | 1000 USD | — | |
|
The court later declined to reconsider its sanction (see here). |
|||||||||
| Source: Robert Freund | |||||||||
| Deleman v. HighLevel | M.D. Pennsylvania (USA) | 25 July 2025 | Pro Se Litigant | Unidentified | N/A | Warning | — | — | |
|
"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." |
|||||||||
| Victor Kholod v. Nationstar Mortgage LLC | M.D. Pennsylvania (USA) | 22 July 2025 | Pro Se Litigant | Implied |
Fabricated
Case Law
(6)
Misrepresented
Case Law
(2)
|
Warning | — | — | |
| Source: Jesse Schaefer | |||||||||