Legal Insights — Advocate Prakhar Gupta Blog

The British Columbia Supreme Court addressed AI hallucinations by self-represented plaintiffs in costs submissions following a successful civil judgment. The plaintiffs cited non-existent cases in their costs arguments, leading Justice Blok to address the AI-generated fabrications in a published costs judgment — one of the first Canadian provincial court decisions to do so.

A Northern District of California court sanctioned a pro se plaintiff after she cited fictitious cases — and then submitted a false explanation to the court, claiming the fabricated citations resulted from ‘editing errors.’ The court found this explanation ‘simply not credible’ and that the plaintiff exacerbated her Rule 11 breach by certifying the fictitious cases as real.

A Pennsylvania federal court addressed large language model (LLM) hallucinations in an immigration detainee’s habeas petition while ordering a bond hearing for the Ghanaian permanent resident. The case is notable for its use of ‘LLM’ terminology in a published immigration decision.

The Pennsylvania Superior Court published a decision in a car loan dispute where court submissions contained AI/LLM-generated citations to cases that do not exist. The Westlaw annotation explicitly identifies large language model (LLM) hallucinations as the source, marking one of the first state appellate courts to use that specific terminology.

A Florida federal court held a sanctions hearing over AI-generated fake citations submitted in two consolidated employment cases, warning that ‘the use of AI as a legal research tool does not alter’ lawyers’ basic ethical obligation to provide true and accurate citations to the court.

A Chicago pro se plaintiff brought Fair Housing Act claims against his landlords, but his filings contained references to cases that do not exist. The N.D. Illinois court granted dismissal of some claims while flagging the hallucinated citations in its published opinion.

The Appellate Court of Maryland flagged non-existent case citations in a divorce appeal brief — citations that did not exist and were likely AI-generated. The Westlaw editor’s note explicitly identifies the decision as containing ‘incorrect or non-existent’ references, a pattern courts are increasingly calling out.

A federal court in Oklahoma warned an attorney that future AI-generated fake citations could lead to sanctions or the striking of filings. Though no sanctions were imposed this time, the court’s rebuke signals escalating judicial intolerance for unverified AI-generated legal research.

A Delaware Court of Chancery judge noted that a petitioner’s brief contained several incorrect citations and warned that the use of generative AI to prepare court submissions without verifying accuracy is harmful to the legal system — even in estate and probate proceedings.