AI Hallucination Cases

See beginning of judgment: "Editor's Note: This decision contains discussion of citation references that are incorrect or do not actually exist. These invalid citations appeared in the original court opinion and have been preserved as written since they are part of the official record. Any links to these invalid citations have been removed."

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."

Plaintiff's opposition brief cited numerous nonexistent cases. Defendant identified the fabricated citations in its reply; plaintiff admitted reliance on an AI-based drafting tool and apologized. The court confirmed several cited cases do not exist but declined to pursue Rule 11 sanctions, finding apology, mitigation, and proportionality concerns.

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

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

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.

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.

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.

Law firm explained what happened here. On October 28, 2025, the court declined to take any action in response to the motion for sanctions.