AI Hallucination Cases

The Court found 28 false or misleading citations across 11 pleadings (14 fabricated, 14 erroneous/misquoted). Mr. Howie admitted use of ChatGPT and failure to verify citations. The Court applied Rule 11(b) and its AI framework (verification, candor/correction, accountability) and imposed sanctions and restitution. Fines of 3,000, 2,000, and 1,000 USD on individual attorneys, plus opposing party's costs and fees,

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.

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.

"One week after filing its second motion for summary judgment, Liberty Mutual submitted a notice of errata identifying the erroneous Goodman and Chaudri citations and demonstrating legitimate citations to those cases. [ECF No. 50].3 While the Court acknowledges Liberty Mutual’s prompt notice disclosing the two most serious errors in its filing, the additional misquotations and mischaracterizations discussed above will not be disregarded. Liberty Mutual indicates that the errors were typographical and/or caused by vision impairment, but that explanation is simply not credible. The errors in Liberty Mutual’s filing are not ones in which a few letters or numbers were passed over or shuffled. Rather, the filing includes entire names, dates, court designations, and Westlaw citations that are completely off base, and various other inaccuracies cannot be explained by typographical or vision issues. Therefore, the Court will reserve its ruling on the motion for sanctions and will set a hearing requiring Liberty Mutual to show cause why it should not be sanctioned."

"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."

(Not an hallucination per se, but worth adding to the database anyway.)

Folllowing a show cause order, Counsel admitted to having used the tool together with Google Search, and explained that, although he was aware of the issues with AI models like ChatGPT, he said he did not expect this tool to fall into the same issues.

The Court found Attorney James A. Johnson used Ghostwriter Legal to draft a motion that contained multiple fabricated case citations, misstated/false quotations attributed to authorities, and cited precedent that had been reversed by the Supreme Court. The Court found the conduct tantamount to bad faith and imposed sanctions under its inherent authority. Sanctions include an order to file, not under seal, this order "in any case in any court wherein he appears as counsel fortwelve (12) months after the date of this order."

The court noted prior fabricated citations in plaintiff's earlier briefing (for which counsel had already been sanctioned). In the current filing the court found no fabricated citations but identified inaccurate legal contentions—e.g., a rule statement claiming withholding ready-to-produce material while seeking extra time is sanctionable under Fed. R. Civ. P. 37(b)—which the court found unsupported and incorrect. The court suspected plaintiff used AI again, but simply removed the citations. The court admonished counsel to review AI-generated work and comply with Rule 11 but did not impose additional sanctions here.

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.

Original Show Cause Order is here.

The grounds of appeal contained at least two non-existent authorities. The judge concluded the false citations likely arose from unchecked generative-AI drafting and directed the solicitor to show cause why conduct should not be referred to the SRA.

Assessing Officer relied on three judicial decisions that the court found to be non-existent. The court observed such citations appear to have been fetched (implicitly) from AI and admonished that quasi-judicial officers must verify AI-generated results before relying on them; held Assessment Order violated principles of natural justice and remanded matter.

Show Cause Order is available here.

Court denied OSC/motion on procedural safe-harbor grounds but found defendants submitted miscited, non-existent, and inapposite authorities (and noted risk of AI-generated fake citations). Defendants accepted responsibility but no sanctions imposed.

"When criminal defense attorneys fail to comply with their ethical obligations, their conduct undermines the integrity of the judicial system. It also damages their credibility and potentially impugns the validity of the arguments they make on behalf of their clients, calling into question their competency and ability to ensure defendants are provided a meaningful opportunity to be heard. Thus, criminal defense attorneys must make every effort to confirm that the legal citations they supply exist and accurately reflect the law for which they are cited. That did not happen here."