The Chief Justice of Texas’ First Court of Appeals issued a concurring opinion specifically to address what appeared to be AI-fabricated citations in a mandamus petition. The concurrence warned that filing documents with fictitious or misleading citations violates counsel’s duty of candour, and thre
Louisiana attorney Ross LeBlanc admitted using EVE AI to draft motions that contained a fabricated quote from a real case. He voluntarily withdrew the briefs and wrote a candid apology letter to the court, acknowledging AI verification failures even where he believed safeguards were in place.
Pennsylvania’s Superior Court decided a grandmother vs. mother custody appeal where the mother’s pro se appellate brief contained AI-hallucinated citations — now flagged by Westlaw’s Editor’s Note. While the court vacated and remanded on substantive grounds (failure to apply the biological parent pr
The Ontario Labour Relations Board addressed AI use in union certification proceedings after the union flagged that the responding employer’s submissions appeared to have been prepared using artificial intelligence. The Board noted the submissions were replete with allegations about the union’s cond
A pro se plaintiff in New York fabricated statutory language and invented quotes from real US Supreme Court cases in insurance filings, leading to a filing injunction under Rule 11 and the court’s inherent authority, with dismissal of all claims.
A pro se Alaska Native shareholder filed a 70-page complaint challenging a 643,000-acre land transfer and subsequent mining leases under ANCSA. The court dismissed the case for lack of federal subject-matter jurisdiction, finding the claims arose under state law despite involving federal statutory l
A pro se petitioner appealing his wrongful removal by the U.S. Army filed briefs stuffed with AI-hallucinated case citations before the Federal Circuit. The court issued a pointed warning: fabricated citations are sanctionable and can result in dismissal, even for self-represented litigants.
California’s First District Court of Appeal published a landmark warning extending AI hallucination sanctions to self-represented litigants after respondent Thomas Panas used generative AI to draft a brief citing two non-existent cases. The court reversed the child support order on the merits while
An S.D.N.Y. Magistrate Judge used the explicit term ‘AI-generated hallucination’ after finding a quoted passage attributed to a real case was not in that case or anywhere on Westlaw. Admonishment issued with a clear verification duty order — and a rare note of judicial empathy for pro se AI use.
A Georgia federal court denied a pro se plaintiff’s motion to strike, noting that the brief cited non-existent cases and explicitly warning that while there is no prohibition on using AI in litigation, pro se litigants must not cite fake opinions — failure to comply with Rule 11 may result in moneta