Artificial Intelligence: AI's Siren Song

Two cases from the Southern District of New York set the tone for considering sanctions when attorneys used AI-generated, unverified case citations. In both cases, the courts exercised discretion in imposing sanctions (Mata) and declining to impose sanctions (Cohen). In both cases, the courts considered traditional jurisprudential standards for Rule 11 from the Federal Rules of Civil Procedure and local rules.

Mata v. Avianca, Inc.

The ruling in Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023) launched a niche area of sanctions for AI-generated citation fabrications. In Mata, the attorneys were sanctioned after submitting fake judicial opinions with fabricated quotes and citations, with one attorney found to have acted in bad faith for not verifying the cited cases and another attorney for intentionally avoiding confirmation of their existence. Id. at 448, 464–66. At the outset, the court observed “[m]any harms flow from the submission of fake opinions” before conducting a deep examination of the filings at issue. Id. at 448 (the court's findings of fact covered ten pages in the reported decision). The court's analysis of the attorneys' conduct under the standards set forth by Rule 11 was equally comprehensive. Id. at 459-66. Ultimately, the court concluded that a penalty of $5,000 was sufficient “to advance the goals of specific and general deterrence.” Id. at 466.

As this section details, Mata has not been an isolated incident. Courts across the country are discovering AI-generated fabrications in legal filings. The litany of cases involving sanctions related to AI indicates that the legal profession blindly created a crisis due to negligence. Attorneys are entering sensitive client information into ChatGPT and other GAI tools, asking AI to draft motions without proper verification, and treating LLMs like traditional legal research platforms such as Westlaw or Lexis.

United States v. Cohen

After pleading guilty to evading income taxes, lying to banks and Congress, and violating campaign finance laws, the defendant filed several motions for early termination of his term of supervised release. United States v. Cohen, 724 F. Supp. 3d 251, 253 (S.D.N.Y. 2024). The fourth motion raised the question whether sanctions should be imposed for that motion's citation to three non-existent cases. Id. In the motion, the defendant's counsel cited and described three ‘‘examples’’ of decisions granting early termination of supervised release that the Second Circuit allegedly affirmed. Id. at 254. The defendant (a disbarred attorney) obtained the cases using Google Bard and provided the cases to counsel, who included the cases in the motion. Id. The defendant believed Google Bard to be a ‘‘super-charged search engine," and not a generative AI service like Chat-GPT. Id. The defendant "trusted" that counsel would vet the additions before including them in the motion. Id. at 254-55. The court considered whether the defendant's counsel acted in bad faith to determine whether sanctions should be imposed. Id. at 258. The court explained that it could only impose sanctions under its inherent authority if there was clear and convincing evidence that a party or counsel knowingly submitted a materially false or misleading filing or knowingly failed to correct false statements. Id. Importantly, this must be part of a deliberate and unconscionable scheme to obstruct the court’s ability to adjudicate the case fairly. Id. While the court found counsel's citation to non-existent cases to be embarrassing and certainly negligent (perhaps even grossly negligent), it ruled that sanctions would not be imposed on counsel. Id. at 258-59. In reaching a decision, the court noted that while the defendant was not subject to the show cause order regarding sanctions, the court opined that sanctions would not be warranted. Id. at 259. The court noted that the defendant was a party to the case and, as a disbarred attorney, was not an officer of the court. Id. Thus, he was entitled to rely on his counsel and to trust his counsel’s professional judgment. Id.

Patient zero for AI hallucination cases occurred at a trial court in Maine. In Scott v. Fed. Nat'l Mortg. Ass'n, No. RE-2023-037, 2023 WL 6935586, at *1 (Me. Super. Ct. June 14, 2023), the pro se plaintiff initiated an action against the defendant regarding property purportedly owned by the plaintiff that was being foreclosed upon by the defendant against a previous owner. The plaintiff claimed ownership of the property through a contract that was executed on December 30, 2022. Id. The defendant commenced the foreclosure proceedings against the previous owner on December 18, 2019, and recorded the complaint on February 19, 2020. Id. The judgment of foreclosure was entered on May 13, 2022, and the foreclosure sale occurred on December 16, 2022. Id. The court granted the defendant's motion to dismiss, concluding that the plaintiff failed to plead facts that would entitle him to relief under any of his alleged theories. Id. at *3. Additionally, the defendant moved for sanctions on the basis that the plaintiff knowingly filed the action without grounds to support his claims and that the plaintiff's response to the motion to dismiss contained citations to non-existent cases. Id. at *4. The court noted recent incidents in the legal community that involved filings generated by AI that incorporate case citations and quotations that do not exist. Id. The court opined that "blind reliance on artificial intelligence does not excuse misrepresentation of the law to the Court." Id. The court further stated that pro se litigants must be held to the same standard as attorneys to verify citations in a court filing pursuant to Maine Rule of Civil Procedure 11. Id. The court ordered the plaintiff to pay the defendant's reasonable attorney fees, costs, and expenses incurred. Id. The court explained that the sanctions were issued to deter future litigants from misusing AI in legal filings. Id.

On appeal, the Supreme Judicial Court of Maine affirmed the trial court's ruling, noting, in part, that "the trial court did not abuse its discretion by imposing sanctions against [the plaintiff] for knowingly filing a pleading without grounds and citing to non-existent legal authority in support of his position." Scott v. Fed. Nat'l Mortg. Ass'n, No. CUM-23-244, 2024 WL 4944206, at *1 (Me. Apr. 23, 2024). Additionally, the Supreme Judicial Court issued a show cause order, requiring the plaintiff to demonstrate why he should not be sanctioned for taking a frivolous appeal. Id. The plaintiff failed to make such a showing, leading to the conclusion that the appeal was frivolous, and the defendant was entitled to reasonable attorney fees and expenses incurred on appeal. Id. 

Digital access to the Maine judicial system is lacking; therefore, it is not possible to find the total sanction amount imposed on the plaintiff.   

In 11 pleadings, the plaintiffs' counsel submitted documents containing fabricated case citations, erroneous citations, quotations of non-existent law, and misstatements of law. Mattox v. Prod. Innovation Rsch., No. 24-cv-235, 2025 WL 3012828, at *1 (E.D. Olka. Oct. 22, 2025). The court found that the use of GAI in preparing these pleadings violated Rule 11(b) and the court's AI guidelines. Id. The court emphasized the need for human verification of AI-generated content and established a framework for evaluating AI-generated filings, focusing on verification, candor, and accountability. Id. at *5. In crafting an appropriate sanction, the court reviewed the litany of cases (many of which are referenced in this research guide or its archive), where other courts imposed monetary sanctions, referred counsel to disciplinary bodies, revoked pro hac vice admissions, and ordered attendance of CLE trainings. Id. at *6-7. The court opined:

The sanction must therefore speak not only to the lawyers before this Court, but to every lawyer tempted to trade diligence for speed. The rule is simple and enduring: truth is not negotiable, and the signature on a pleading still means something.

Id. at *7. The court imposed penalties on individual attorneys based on their roles. Id. at *8-9.

The "Signing and Drafting Attorney" received a monetary sanction of $3,000 and a public reprimand by the court; the court declined to refer this attorney to the state bar, finding "no intentional deception warranting referral." Id. at *8. The court permitted this attorney to "remain as counsel of record, subject to the continuing duty to verify all future filings personally and to certify compliance with this Order." Id.

The "Referring Counsel and Active Participant" received a monetary sanction of $2,000 and a public reprimand by the court; the court declined to refer this attorney to the state bar, "reflect[ing] his secondary role while reaffirming that supervision is a duty, not a courtesy." Id.

The "Managing Partner (pro hac vice)" received a monetary sanction of $1,000 and a public reprimand by the court. Id. The court declined to refer this attorney to the state bar, because "[t]he sanction recognizes limited direct involvement yet underscores that firm leaders remain guardians of their name and their firm's reputation on every pleading." Id.

As for "Local Counsel of Record," the court observed that the attorney's "neglect as local counsel did not create the hallucinated authorities, but it enabled them." Id. The court issued a formal public reprimand and ordered that the attorney "may not serve as sponsoring or local counsel for any pro hac vice attorney in the Eastern District of Oklahoma" for 12 months. Id. at *9.

Additionally, the court struck the 11 filings and ordered the plaintiffs to file verified amended pleadings. Id. Finally, the court ordered the plaintiffs' law firms to remit $23,496.90 in attorney fees and costs to opposing counsel. Id. at *10. 

The court concluded:

The Court has imposed sanctions to restore, not to ruin. The aim of this ruling is not punishment for its own sake, but the reaffirmation of professional honor.

All counsel have appeared, accepted responsibility, and sought mercy. The Court has answered with proportion, acknowledging their contrition while ensuring accountability endures. The combination of public reprimand, restitution, and monetary penalty satisfies the Rule 11 standard of deterrence and reaffirms that the practice of law is an act of trust.

The lesson is neither new nor novel. The practice of law has never been about convenience; it has always demanded courage. The quiet, disciplined courage to stand for what is right when compromise would be easier. Marcus Aurelius wrote, “If it is not right, do not do it; if it is not true, do not say it.” Meditations bk. 12, § 17 (Gregory Hays trans., Modern Library ed. 2002). That simple maxim captures the heart of advocacy: the moral courage to write, to argue, and to sign only what truth can defend.

It takes courage to put a word, a sentence, a phrase to paper in defense of another. It takes courage to sign one's name beneath arguments that carry the weight of justice. Machines can assemble words, but they cannot believe in them. They can process information, but they cannot possess conviction.

The Court does not fear progress. It fears abdication. When lawyers trade reflection for automation, they surrender the very quality that makes their words worthy of belief. The oath of candor is not a relic; it is the living covenant between the advocate and the tribunal. It binds judgment to integrity and intellect to honor.

Generative tools may assist, but they can never replace the moral nerve that transforms thought into advocacy. Before this Court, artificial intelligence is optional. Actual intelligence is mandatory.

Id. at *10-11 (quoting Marcus Aurelius, Meditations bk. 12, § 17 (Gregory Hays trans., Modern Library ed. 2002)).

In United States v. McGee, No. 24-cr-113, slip op. at 1 (S.D. Ala. July 10, 2025), Dkt. No. 258, the court addressed the defendant's motion to continue the trial; the prosecution opposed and alleged that the defendant's filing contained fabricated legal citations. According to the prosecution, the inability to locate the purportedly fake citations "bear the hallmarks" of AI hallucinations. Id. The court conducted an independent search and found similar issues; consequently, defense counsel was ordered to show cause why sanctions should not be imposed for making false statements of fact or law. Id. at 2. The court subsequently granted the defendant's motion to remove counsel and to appoint new counsel. Oral Order, McGee, No. 24-cr-113 (S.D. Ala. Jul. 16, 2025), Dkt. No. 268.

Subsequently, the court determined that counsel's conduct was tantamount to bad faith, as he failed to verify the citations generated by the AI program before submitting them to the court. McGee, No. 24-cr-112, 2025 WL 2888065, at *7 (S.D. Ala. Oct. 10, 2025). The court found that counsel's "misconduct [was] tantamount to bad faith and sanctionable under the Court's inherent authority." Id. at *8. The court decided to reprimand counsel for the misconduct. Id. at *9. The reprimand included the following. Id.

• Counsel shall file, not under seal, a copy of the order in any case in any court wherein counsel has appeared and final judgment has not been entered.
• Counsel shall file, not under seal, a copy of the order in any case in any court wherein counsel appears for 12 months after the date of this order.
• Counsel shall provide a copy of the order to any jurisdiction under which he is licensed to practice law within two business days of the issuance of this order. 
• Counsel shall further file a notice of compliance with the court no later than the third business day.
• The clerk shall send a copy of the order to the Alabama bar for review. 
• The court recommended that the public reprimand and sanctions contained within the order be the final action with regard to these particular allegations and facts.
• The clerk shall send a copy of the order to the chief judges for the Northern District of Alabama and the Middle District of Alabama.
• Finally, the court directed the clerk to submit this order for publication in the Federal Supplement.

In this case, the court found that the defendant’s motion to dismiss included briefs containing erroneous quotations and misrepresented case law, including inaccurate quotes attributed to the court’s own prior opinion. Jakes v. Youngblood, No. 24-cv-1608, 2025 WL 2371007, at *1-2 (W.D. Pa. June 26, 2025) (emphasis added). While the plaintiff identified these issues in a response brief, the defendant did not offer an explanation. Id. The court noted that the defendant's counsel "brazenly attempted to mount a tu quoque defense, asserting that 'a LexisNexis Document Analysis of Plaintiff's own opposition brief reveals a pattern of misquotation, superficial citation, and invocation of authorities that are either inapposite or do not support the propositions for which they are cited.'" Id. The court independently reviewed each party's filings, finding no issues with the plaintiff and that the defendant's "brief [was] replete with non-existent quotations and repeated misrepresentations of actual case law." Id. The court opined, "when accused of a serious ethical violation, [the defendant's counsel] chose to double down." Id. The court viewed this conduct "as a clear ethical violation of the highest order." Id. The court identified eight specific fabrications and numerous additional fabricated quotations. Id. at *2-4. The court graciously presumed that the defendant's briefs were constructed by GAI rather than an effort by the defendant's counsel to personally construct false and misleading briefs." Id. at *4. The court concluded that counsel could not "outsource his obligations to the court and his client to a third party--including artificial so-called 'intelligence.'" Id. The court struck the defendant's motion to dismiss and reply brief from the record and ordered the defendant to answer the complaint by a specified time. Id. While counsel filed a withdrawal of his appearance, the court ordered counsel to show cause as to why sanctions should not be imposed. Id. at *1, *5.

At a subsequent show cause hearing, the court requested the plaintiff to submit a petition for attorney fees. Plaintiff's Petition for Fees at 11, Jakes, No. 24-cv-1608, (W.D. Pa. Aug. 1, 2025), Dkt. No. 61. The plaintiff requested $76,197.63 in attorney fees. Id. at 11. To support the award of attorney fees, the plaintiff argued that the defendant's AI-infected 20-page motion to dismiss raised eight separate issues—far more substantial than typical AI-related cases (usually involving lower-stakes filings like discovery disputes). Id. The defendant further complicated the matter by employing the same strategy in his reply brief, inaccurately accusing opposing counsel of similar misconduct. Id. The plaintiff asserted that this situation necessitated the filing of a sur-reply. Id.

In the subsequent memorandum Order, the court found that the attorney's explanation regarding the AI misuse was not credible. Jakes, No. 24-1608, slip op. at 2 (W.D. Pa. Oct. 6, 2025), Dkt. No. 71. Notably, the court specifically opined that an attorney "with a cosmopolitan, multi-state, practice—cannot plead ignorance to justify their use or misuse of AI in drafting legal documents filed with the courts." Id. The court noted that the defendant's brief in support of the motion to dismiss and the reply contained fabrications, but the attorney refused to accept responsibility and instead wrongly accused opposing counsel of AI misuse. Id. While the court directed opposing counsel to submit a petition for fees, the court determined that the requested amount ($76,197.63) was not "a reasonable measure of a sanction in this case." Id. at 4-5. In determining a reasonable amount, the court considered the nature of the attorney's practice and ability to pay. Id. at 5. The court "believe[d] that monetary sanctions [were] necessary to deter [the attorney] from future misconduct—especially due to his decision to double-down on his misuse of AI after it was brought to the attention of the Court." Id. Ultimately, the court found that a fee award to opposing counsel in the amount of $5,000 was appropriate. Id.

In Pelishek v. City of Sheboygan, No. 23-cv-1048, 2025 WL 2062027, at *2 (E.D. Wis. July 23, 2025), the plaintiff filed a lawsuit against the defendants, alleging violations of his First Amendment rights, Title VII claims, and equal protection violations. The plaintiff and the defendants both moved for summary judgment. Id. The court denied the defendants' motion for summary judgment as to the plaintiff's First Amendment claim, but granted the motion with respect to the plaintiff's other claims. Id. at *21. With respect to the plaintiff's motion, the court opined: 

In light of counsel's persistent and egregious misrepresentations, [the plaintiff's] motion for summary judgment will be denied. This is not a sanction for counsel's apparent misconduct; the court will address that matter later. Rather, the denial of [the plaintiff's] motion for partial summary judgment reflects merely that, by presenting a brief riddled with material errors, [the plaintiff's attorneys] have failed to satisfy their burden to show that no genuine dispute of material fact exists and that [the plaintiff] is entitled to partial summary judgment.

Id. at *6. The court also noted that the plaintiff's response brief to the defendants' motion for summary judgment was "replete with misrepresentations." Id. While the court's opinion did not explicitly reference AI-generated content, it contained a litany of significant errors in legal citations. Id. at *8-9. Other courts acknowledged that such errors were indicia of AI hallucinations. The court ordered the attorneys to show cause as to why sanctions (including dismissal) should not be imposed. Id. at *9. Additionally, the court noted its duty to inform the relevant authority if it knows that attorneys violated the Rules of Professional Conduct, raising significant concerns about the attorneys' honesty or fitness. Id. at *10. 

In responding to the show cause order, the senior attorney blamed the junior attorney for all the errors, stating that he had no role in drafting the relevant documents. Pelishek, No. 23-cv-1048, 2025 WL 2675094, at *1 (E.D. Wis. Sep. 18, 2025). The junior attorney blamed her inexperience for the errors; she essentially argued that she was not dishonest but merely incompetent. Id. In deciding whether to impose sanctions, the focus for the court turned on the attorneys' misconduct, which included misrepresentations of law and fact in court filings. Id. at *2. In applying a Rule 11 analysis, the court considered whether these actions were willful or negligent, part of a pattern, and the impact on the litigation process. Id. Ultimately, the court decided against the most severe sanction of dismissal, opting instead for monetary sanctions to deter future misconduct. Id. at *4-5. In a fascinating twist, the attorneys engaged in similar conduct in at least one other case. See Coomer v. Lindell, No. 22-cv-01129, 2025 WL 1865282 (D. Colo. July 7, 2025). In that case, the court imposed monetary sanctions in the amount of $3,000 on each attorney. Id. at *9. The Coomer court noted that the amount was consistent with sanctions imposed by other courts for similar misconduct. Id. at *9. In this case, the court opined:

If this court accepted the explanation that plaintiff's counsel provided in the Colorado case, it would mean that by at least February 25, 2025—that date they filed their brief in the Colorado action—they had first-hand knowledge of the danger of artificial intelligence hallucinating cases and misrepresenting holdings. After all, they allegedly recognized the misrepresentations in that case and removed them only to have [the junior attorney] mistakenly file an uncorrected draft. Yet, despite knowing that they were employing artificial intelligence in a way that may result in fabricated caselaw, [the attorneys] submitted their brief in support of their motion for summary judgment in this case a week later (and their response to the defendants’ motion over a month later), apparently without verifying all of their citations.

Pelishek, No. 23-cv-1048, 2025 WL 2675094, at *3 (E.D. Wis. Sep. 18, 2025). Notwithstanding the court's concern over the "perils of artificial intelligence," the senior attorney received a sanction of $4,000, and the junior attorney's sanction amounted to $500. Id. at *2, *5-6.

Following a show cause hearing, the magistrate judge issued a report and recommendation that the plaintiff's attorney should be personally sanctioned for filing a brief that contained non-existent case citations. Davis v. Marion Cnty. Super. Ct. Juv. Det. Ctr., No. 24-cv-1918, 2025 WL 2502308, at *5 (S.D. Ind. Sep. 2, 2025). The attorney admitted responsibility for the errors, attributing them to a short deadline and his reliance on a paralegal to draft the brief. Id. at *1. The magistrate judge found that the attorney did not verify the citations using available legal research tools (the attorney represented that he subscribed to Lexis). Id. at *2. The magistrate judge opined: "It would have taken only a few minutes to check the validity of the citations in the brief using LEXIS before filing it." Id. The magistrate judge recommended sanctions against the attorney for failing to ensure the accuracy of the information provided in the relevant court filing, emphasizing that the use of AI tools in drafting legal documents was not inherently improper. Id. The magistrate judge explained that the responsibility lay with the attorney to verify the accuracy of the citations, regardless of whether AI was used. Id. at *3. The court noted that hallucinated cases created by GAI tools were widely discussed, but the attorney's paralegal claimed to have used Fastcase instead of AI. Id. at *2. The magistrate judge recommended a $7,500 sanction for the Rule 11 violations and referred the matter to the chief district judge for further consideration of any additional discipline. Id. at *5. 

In a miscellaneous action to address the referral, the chief district judge subsequently referred the matter to the state disciplinary commission. In re Sture, No. 25-mc-47 (S.D. Ind. Sep. 8, 2025), Dkt. No. 73. In objecting to the magistrate's recommendation, the attorney asserted that referral to the disciplinary commission was a sufficient deterrent and that monetary sanctions were not warranted. In re Sture, No. 25-mc-47, slip op. at 1 (S.D. Ind. Oct. 10, 2025), Dkt. 94. The chief district judge concluded that this miscellaneous case only addressed the disciplinary referral, and not any potential Rule 11 sanctions; the attorney's objections were denied. Id. at 2.  

In a ten-count complaint, an incarcerated plaintiff alleged Eighth Amendment deprivations and negligence against the defendants (prison officials and officers with the Alabama Department of Corrections). Complaint at 1-2, 34, 45, 49, 51, 55, 58, 60, 63, 64, 77, Johnson v. Dunn, No. 21-cv-1701 (N.D. Ala. Dec. 27, 2021), Dkt. No. 1. During discovery, the defendant moved to depose the plaintiff; the plaintiff opposed the motion on the basis that counsel could not adequately prepare to present the plaintiff in the specified time frame and that the defendant cited "no legitimate authority" to support the proposition that such a deposition was appropriate. Plaintiff's Response to Defendant's Motion for Leave to Depose Incarcerated Persons, at 1, Johnson, No. 21-cv-1701 (N.D. Ala. May 15, 2025), Dkt. No. 186 (emphasis in original). The plaintiff claimed that the defendant's argument supporting the appropriateness of such a deposition was fabricated: the defendant's legal authority "appear[ed] to have been made up out of whole cloth." Id. at 2 (emphasis in original). The plaintiff accused the defendant of fabricating case law and argued that the defendant's motion should be denied for failing to cite any legitimate case law to support their position. Id. at 5 (emphasis in original). The court conducted an independent investigation of the case citations in the defendant's motion and could not locate the cases. Johnson, No. 21-cv-1701, 2025 WL 1465778, at *1 (N.D. Ala. May 16, 2025), Dkt. No. 187. The court issued a show cause order as to why sanctions should not be imposed "for making false statements of fact or law." In issuing the order, the court noted that four attorneys signed the defendant's motion. Id. Following a subsequent show cause hearing, the court ordered initial briefing to be completed by June 2, 2025. Johnson, No. 21-cv-1701 (N.D. Ala. May 21, 2025), Dkt. No. 199.

In determining an appropriate sanction, the court noted that this case "demand[ed] substantially greater accountability than the reprimands and modest fines that have become common as courts confront this form of AI misuse." Johnson, No. 21-cv-1701, slip op. at 1 (N.D. Ala. July 23, 2025), Dkt. No. 204. The court underscored the urgency to impose greater accountability by declaring: 

[T]ime is telling us – quickly and loudly – that those sanctions are insufficient deterrents. In principle, they do not account for the danger that fake citations pose for the fair administration of justice and the integrity of the judicial system. And in any event, they have little effect when the lawyer’s client (here, an Alabama government agency) learns of the attorney’s misconduct and continues to retain him.

Id. at 2.

The court publicly reprimanded the three attorneys for making false statements. It ordered the publication of the reprimand, disqualified the attorneys from any further involvement in this case, and referred the matter to the state bar and other relevant licensing authorities. Id. Additionally, the court directed the clerk to submit this order for publication in the Federal Supplement. Id. at 50. Docket.

See also Ralph Artigliere & William Hamilton, Reasonable or Overreach? Rethinking Sanctions for AI Hallucinations in Legal Filings, JDSupra (Aug. 18, 2025).

In Noland v. Land of the Free, L.P., 336 Cal. Rptr. 3d 897, 901 (Cal. Ct. App. 2025), the plaintiff's appeal of a summary judgment ruling, which did not present novel legal questions or unique factual circumstances, was largely straightforward and typically would not merit publication. However, the plaintiff's opening appellate brief and reply oozed with hallucination-riddled AI slop. The court stated: “nearly all of the legal quotations in plaintiff's opening brief, and many of the quotations in plaintiff's reply brief, are fabricated.” Id. In total, the appellant's opening brief included 23 case quotations, 21 of which were fabricated. Id. at 905. The appellant's reply brief contained even more fabricated quotations. Id. The court found that both briefs were filled with inaccurate citations that do not support the claims for which they were cited. Id. While the extensive reliance on non-existent legal authority would justify striking the appellant's opening brief or dismissing the appeal, the court, sua sponte, issued an order to the plaintiff's attorney to show cause why sanctions should not be imposed "for filing appellate briefs replete with fabricated quotes and citations." Id. at 905, 909. The attorney admitted to relying on AI for legal citations and acknowledged that he was unaware of its tendency to fabricate quotes, which he did not verify against more reliable sources. Id. at 909. The court found that the attorney's reliance on fabricated legal authority rendered this appeal frivolous and violated the state's rules of court. Id. at 910. The attorney admitted that his briefs contained fabricated legal authority due to his reliance on AI sources like ChatGPT, Claude, Gemini, and Grok, and he acknowledged that he was previously unaware of the issue of AI hallucinations but has since educated himself about the issue. Id. at 910-11. In the opinion, the court laid out the history of AI hallucinations infecting court filings over the past two years. Id. at 911. The court specifically noted that one article provided that the AI hallucination problem was becoming worse, specifically referring to OpenAI's newest models, which hallucinated 30 to 50 percent of the time. Id. The court reviewed the numerous decisions confronting AI-generated authorities, which concluded that filing briefs with fabricated legal authority was sanctionable. Id. at 911-12. The court was dubious of the attorney's claim of ignorance regarding AI hallucinations: "the problem of AI hallucinations has been discussed extensively in cases and the popular press for several years." Id. at 913. The court opined that "even a superficial review of the literature would have alerted counsel to this issue." Id. Notably, the court rejected the attorney's suggestion that his conduct was not sanctionable because some of the assertions were supported by accurate legal citations, and other misattributed assertions found support in cases he did not cite. Id. at 913-14. The court admonished the attorney by stating that its function was not to serve as the attorney's "backup appellate counsel." Id. at 914. The court deemed the appeal frivolous due to its weak legal basis, reliance on fabricated citations, and failure to provide proper support for its points with legitimate legal authority. Id. The court imposed sanctions on the attorney, ordering him to pay a $10,000 penalty, directing the clerk to forward the opinion to the state bar, and requiring the attorney to provide a copy of the opinion to his client. Id. at 915. The court declined to award sanctions to opposing counsel, noting they failed to alert the court to the fabricated citations and only became aware of them after the order to show cause. Id. (emphasis added).

See Robert Ambrogi, A New Wrinkle in AI Hallucination Cases: Lawyers Dinged for Failing to Detect Opponent’s Fake Citations, LawSites (Sep. 16, 2025) (discussing whether attorneys now have a duty to detect and report their opponents’ AI-generated fake citations); see also Y. Peter Kang, Calif. Court Issues AI Hallucinations 'Warning,' Sanctions Atty, Law360 (Sep. 15, 2025).

In an action against the Social Security Administration, the court addressed citation-related deficiencies in the plaintiff’s opening brief, which included references to non-existent cases and misquoted authorities, suggesting the use of AI in drafting the brief. Mavy v. Comm'r of SSA, No. 25-cv-689, 2025 WL 2355222, at *1 (D. Ariz. Aug. 14, 2025). Upon reviewing the brief, the court found that most of the citations were either non-existent or did not support the propositions for which they were cited, indicating a failure to conduct a reasonable inquiry into the validity of the legal authorities. Id. at *4, *6. The court opined:

After considering the volume of ever-expanding case law and the particular facts of this case, the Court finds that Counsel violated Rule 11(b)(2). By repeatedly citing this Court to non-existent “cases” and to actual cases that did not support the propositions for which they were cited, Counsel failed to conduct any review whatsoever that those cases were valid or that the arguments she was making were legally tenable. That conduct squarely runs afoul of Rule 11’s mandate.

Id. at *6.

The court concluded that sanctions were warranted, finding that the plaintiff's opening brief was "riddled with fabricated, misleading, or unsupported citations." Id. at *7. The court further opined:

This situation is indeed akin to contempt of court. Left with the surviving authority, entire sections of the filing's “Analysis” are nearly wholly unsupported, and clearly, there was no reasonable inquiry made into its contents. 

Id.

In crafting a sanction, the court was "somewhat heartened" by the attorney's statement that she implemented heightened procedures to ensure this conduct would not be repeated. Id. at *10. Nevertheless, the court emphasized that the record established that the attorney failed to follow the review process for the purpose of complying with Rule 11. Id. The court imposed the following sanctions: 1) revoking the attorney's pro hac vice status and removing her from the case; 2) striking the plaintiff's opening brief; 3) ordering the attorney to promptly serve a copy of this order on the plaintiff; 4) ordering the attorney to write letters to the three judges to whom she attributed fictitious cases; 5) ordering the attorney to transmit a copy of this order to every judge presiding over any case in which the attorney is of record; 6) directing the clerk to serve a copy of this order on the Washington State Bar Association. Id. Additionally, the court ordered the attorney to serve a copy of this order on any other state's bar office of which she may be a member. Id.

Some AI slop oozed into Florida by way of Canada, resulting in a significant sanctions award. The case began in Canada when the Quebec-based Promark initiated an action, alleging a breach of contract claim against ByoPlanet for unpaid products sold and delivered in 2020. The court awarded Promark more than $6 million (CAD), the additional statutory indemnity, and expert fees. Promark Elecs. Inc. v. ByoPlanet Int'l LLC, 2024 QCCS 788, at paras. 1, 49 (Can.). Moreover, the court declared Promark may proceed to prove its damages at a subsequent hearing in lieu of ByoPlanet's abusive filing. Id. at paras. 200, 202, 204-05. In a subsequent proceeding, the court granted Promark's application for fees and disbursements incurred, as well as for punitive damages (specifically ordering ByoPlanet's CEO to pay $150,000 (CAD) in punitive damages). Promark Elecs. Inc. v. ByoPlanet Int'l LLC, 2024 QCCS 1930, para. 59, 62 (Can.).

Later, Promark recorded the Canadian court's judgment in Broward County, Florida, and initiated an action to enforce the judgment pursuant to state law. Fla. Stat. § 55.601 et seq. (2025). In response, ByoPlanet spun a web of multiple cases in Florida (four in state court and four in federal court), using the same attorney in each case. ByoPlanet Int'l, LLC v. Gilstrap, No. 25-cv-60647, 2025 WL 2091025, at *2 (S.D. Fla. July 17, 2025). The four federal cases were consolidated, which resulted in a show cause hearing when ByoPlanet's counsel “repeatedly used AI to hallucinate cases and quotations in his filings [in the states and federal cases].” Id. at *3. At the show cause hearing, the court opined that counsel "created a 'train wreck' with the oversight." See David Minsky, Fla. Judge Tosses Suits Over Errors In AI-Generated Filings, Law360 (July 17, 2025).

After an extensive review of the Promark-ByoPlanet saga, the court explained:

Simply put, [counsel] did not act as a reasonable attorney—not even close. A reasonable attorney does not blindly rely on AI to generate filings. A reasonable attorney, when made aware that his practices were leading to hallucinated cases and quotations, immediately changes course. A reasonable attorney does not rely on a paralegal to draft a filing. The conclusion that [counsel] failed to act as a reasonable attorney is unfortunate, but undeniable. [Counsel] acted in bad faith for an improper purpose. 

ByoPlanet, No. 25-cv-60647, 2025 WL 2091025, at *9.

Ultimately, the court sought to (and did) send a strong message to deter improper attorney conduct. Id. First, the court dismissed the four federal cases without prejudice and without leave to amend, as well as denying any pending motions and terminating all pending deadlines. The judge also ordered that any refilings of these cases by the plaintiffs would be assigned to the present court. Id. at *10. Substantially, the judge ordered counsel to pay the attorney fees in all four federal cases for time spent responding to any filing in which GAI was used to develop hallucinated cases and fabricated quotations. Id. Additionally, if counsel files any case in the Southern District of Florida within the next two years of the instant order, he must attach a copy of this order to any complaint. Id. at *11. Finally, the judge referred counsel to the Florida Bar for appropriate discipline. Id.

Subsequently, the court reviewed the negotiations for each of the four consolidated cases, noting that the asserted attorney fees and costs for the defendants amounted to $85,567.75. ByoPlanet Int'l, LLC v. Gilstrap, No. 25-cv-60647, slip op. at 4 (S.D. Fla. Aug. 1, 2025), Dkt. No. 37. After reviewing the parties’ submissions, including the defendants’ schedules of fees and counsel's objections, the court found that the discounted fees and costs were reasonable based on prevailing market rates and that the defendants’ concessions were sufficient to account for any work that may have fallen outside the scope of this sanctions order. Id. at 9.

In a dispute between the debtor and one of the creditors, the bankruptcy court addressed the creditor's plan objection and the debtor's corresponding response. In re Martin, No. 24-bk-13368, slip op. at 1 (Bankr. N.D. Ill. June 11, 2025), Dkt. No. 56. In the response brief, the debtor argued that the creditor lacked standing to object to the plan's treatment of other creditors if it did not directly affect the creditor. Id. The debtor cited four cases to support this argument; however, the court found these cases to be problematic. Id. at 1-3. Upon reviewing the cases, the court determined that none contained the legal authority that the debtor relied upon, noting that one case did not exist at all. Id. at 3. The court expressed concern that if the debtor's counsel fabricated quotations to mislead both the creditor and the court, this would raise serious issues. Id. Furthermore, the court remarked that if these fabricated quotations originated from unchecked AI sources rather than honest research errors, the situation would be even more alarming. Id. The court referenced several now-infamous cases where the use of AI by counsel led to citations of non-existent authorities, resulting in sanctions. Id. Although the court acknowledged that the debtor's citations to seemingly fabricated quotations supported a non-controversial proposition, the apparent misconduct of the debtor's counsel could not be dismissed. Id. Consequently, the court ordered counsel to show cause as to why sanctions should not be imposed for submitting a brief that appeared to contain manufactured case law. Id. at 3-4.

Following a show cause hearing, the court acknowledged the remorse from the attorney and the firm, but nonetheless concluded that the violation of Federal Rule of Bankruptcy Procedure 9011 warranted sanctions. In re Martin, 670 B.R. 636, 638 (Bankr. N.D. Ill. 2025). In reaching a decision, the court noted that the attorney claimed ignorance in that "he didn't know the use of AI in general and ChatGPT in particular could result in citations to fake cases." Id. at 646. The court found the attorney's position troubling, as GAI has been a "hot topic in the legal profession since at least 2023." Id. at 647. The court opined that "no lawyer should be using ChatGPT or any other generative AI product to perform research without verifying the results." Id. at 648. In a footnote, the court referred to six cases, from Mata to Coomer, to craft a sanction. Id. at 644-46 n.5. While the court considered a larger sanction sum, a sanction of $5,500 (against the attorney and law firm, jointly and severally) was sufficient in lieu of the candor and remorse by the attorney and law firm. Id. at 650. The court also ordered the attorney and at least one member from the law firm to attend a specific AI session at the upcoming National Conference of Bankruptcy Judges. Id. at 650-51. 

An insurance coverage dispute, where the plaintiff alleged breach of contract and bad faith by the defendant, would result in one of the most severe AI-sanction cases reported thus far. See Complaint attached as Exhibit A to Defendant's Notice of Removal, at 3-4, 16-17, Lacey v. State Farm Gen. Ins. Co., No. 24-cv-5205 (C.D. Cal. June 20, 2024), Dkt. No. 1-1. During the proceedings, the court appointed a special master to facilitate discovery. Lacey, No. 24-cv-5205, 2025 WL 1363069, at *2 (C.D. Cal. May 5, 2025), Dkt. No. 119. The parties submitted briefs regarding the discovery issue; the plaintiff's supplemental brief contained numerous problematic legal citations and quotations. Id. The special master immediately recognized that "the source of this problem was the inappropriate use of, and reliance on, AI tools." Id. at *3.

As the special master investigated the matter, involving two law firms acting on the plaintiff's behalf, it was revealed that an attorney at one firm used AI tools to prepare research for the brief, and that document contained the problematic material. Id. The other firm used the research to prepare and file the brief. Id. Those attorneys did not know that the researching attorney used AI; moreover, they did not ask that attorney to use AI. Id. However, the special master found that "[n]o attorney or staff member at either firm apparently cite-checked or otherwise reviewed [the] research before filing the brief." Id. Ultimately, the special master determined that bad faith existed and imposed sanctions. Id. at *7-8. In making a decision, the special master opined:

Even with recent advances, no reasonably competent attorney should out-source research and writing to this technology—particularly without any attempt to verify the accuracy of that material. And sending that material to other lawyers without disclosing its sketchy AI origins realistically put those professionals in harm’s way.

Id. at *7.

Ultimately, the special master imposed severe sanctions. First, the special master struck the plaintiff’s filings on the discovery issue. Id. at *8. Next, the special master noted the court’s order requiring the defendant to pay the costs associated with the discovery issue. Id. However, that order also expressly authorized the special master to shift fees if appropriate; the special master opted to do so, ordering the plaintiff’s attorneys to pay the fees (approximately $26,1000). Id. Finally, the special master considered ordering the plaintiff’s attorneys to compensate the defendant for time spent preparing related briefs. Id. at *9. While the defendant’s attorneys attested that the fees approached $25,000, the special master directed the plaintiff’s attorneys to pay the defense $5,000 for incurred fees. Id.

The special master specifically reflected that the plaintiff was not at fault for “the AI debacle,” but she “will bear this outcome as a consequence of her lawyers’ actions.” Id. at *10. Accordingly, the special master reiterated that the attorneys would be responsible for the monetary awards set forth in the order. Id. The case ultimately settled. Lacey, No. 24-cv-5205, slip op. at 1 (C.D. Cal. July 24, 2025), Dkt. No. 146.

See Robert Ambrogi, AI Hallucinations Strike Again: Two More Cases Where Lawyers Face Judicial Wrath for Fake Citations, LawSites (May 14, 2025). Docket.

In Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol, No. 23-cv-01203 (D.P.R. Apr. 26, 2023), Dkt. No. 1, the plaintiffs alleged that the defendants conspired to restrict sanctioned tournaments and matches in Puerto Rico, thereby stifling competition and limiting the growth of independent leagues. The plaintiffs filed several documents in preparation for a settlement conference. See Puerto Rico Soccer League, No. 23-cv-01203, Dkt. Nos. 160, 174-177. Subsequently, the defendants claimed that the plaintiffs utilized GAI and cited non-existent or erroneous authorities in their recent court submissions. Puerto Rico Soccer League, No. 23-cv-01203 (D.P.R. Mar. 19, 2025), Dkt. No. 187. Upon conducting an independent review, the court found that four of the plaintiffs' motions contained multiple incorrect citations referencing cases that could not be located and presumably do not exist. Id. The court acknowledged that the use of GAI was not prohibited; however, attorneys have a duty to demonstrate competence to their clients and a duty of candor to the tribunal. Id. Consequently, the court ordered the plaintiffs to file a memorandum explaining why sanctions should not be imposed on them for violations of Rule 11 and professional conduct standards. Id. 

In response, the plaintiffs proclaimed that AI was not used in drafting the filings at issue; rather, the various errors occurred due to "human oversight under significant time constraints." Puerto Rico Soccer League, No. 23-cv-01203, slip op. at 3 (D.P.R. Apr. 10, 2025), Dkt. No. 206 (internal quotations omitted). The court found the plaintiffs struck "a defiant and deflective tone" in their response, and was not persuaded by their arguments to avoid sanctions. Id. at 6, 9. According to the court, "[w]hether generative artificial intelligence was used or not is immaterial, what matters is that the Plaintiffs provided the Court with a litany of inaccurate information in support of their claims." Id. at 7. In its opinion and order, the court meticulously scrutinized the 55 erroneous citations contained in the plaintiffs' filings. Id. at 11-37. in considering sanctions, the court reflected that an award of attorney's fees would be appropriate, in part, given the "time and energy required by Defendants and the Court to fact-check Plaintiffs' filings." Id. at 5, 8. Accordingly, the court ordered the plaintiffs to pay the defendants' fees incurred related to the filings at issue. Id. at 10. The court granted the defendants 21 days to submit an itemized application for attorney's fees. Id.

Pursuant to the court's order, the defendants submitted an application for attorney fees. FIFA’s Application For Attorneys’ Fees, Puerto Rico Soccer League, No. 23-cv-01203 (D.P.R. May 5, 2025), Dkt. No. 235. The amount of attorney time and dollar amounts were redacted in the defendants' application. Id. at 1-2, 4, 6, 8-9, 12-13. However, a formatting error in the application revealed that the defendants sought more than $50,000 for time spent responding to the plaintiffs' AI-hallucination-riddled filings. The court ordered the defendants to respond to the plaintiff's attorney fee application by June 18, 2025. Puerto Rico Soccer League, No. 23-cv-01203 (May 7, 2025), Dkt. No. 239. 

In a motion for reconsideration, the plaintiffs requested that the court vacate the sanctions. Plaintiffs' Motion for Reconsideration of Order Imposing Sanctions at 10, Puerto Rico Soccer League, No. 23-cv-01203 (July 28, 2025), Dkt. No. 275. The court denied the motion, ruling that the plaintiffs had failed to identify a manifest error of law, newly discovered evidence, or any other circumstance, such as a change in controlling law, that warranted granting their motion for reconsideration.  Puerto Rico Soccer League, No. 23-cv-01203 (D.P.R. Aug. 6, 2025), Dkt. No. 278 (citing United States v. Pena-Fernandez, 394 F. Supp. 3d 205, 207 (D.P.R. 2019)).

See also Madison Arnold, FIFA Seeks Fees After Citation Mistakes In Antitrust Case, Law360 (May 2, 2025). Docket.

In Park v. Kim, 91 F.4th 610, 612–13 (2d Cir. 2024), the Second Circuit affirmed the trial court's dismissal of the plaintiff's case, citing the plaintiff's attorney's repeated non-compliance with discovery orders. Another significant issue on appeal was that a reply brief filed by the plaintiff’s attorney referenced a non-existent case generated by ChatGPT. Id. The Second Circuit emphasized that attorneys must ensure the accuracy of their submissions and found the attorney's performance lacking, including a late submission containing only two case references, one of which was fabricated. Id. at 613-15. The Second Circuit referred to Mata to highlight that a fictitious opinion does not constitute existing law. Id. at 615. The Second Circuit referred the plaintiff's attorney to the Grievance Panel for potential disciplinary action due to a false statement of law in the brief and a failure to validate the arguments as required by Rule 11. Id. at 615-16.

In an unrelated case, the sanctioned attorney in Park (the plaintiff in this case) filed a pro se action against Delta Airlines to redress racially discriminatory conduct that the plaintiff allegedly suffered when flying as a passenger on a Delta flight. Lee v. Delta Airlines, No. 20-CV-01705, 2023 WL 9184679, at *1 (E.D.N.Y. Mar. 14, 2023). The case was ultimately disposed of via motion practice in favor of Delta. Lee, No. 20-CV-01705, 2024 WL 1230263, at *8 (E.D.N.Y. Mar. 22, 2024). In making a decision, the court expressed "serious concern" that at least one of the plaintiff's case citations was non-existent and may have been the product of GAI hallucinations. Id. at *3. The court specifically referenced the plaintiff's conduct in Park. Id. While the court did not impose sanctions, the lesson cannot be clearer for attorneys: check your work!

Platforms like ChatGPT are powered by “large language models” that teach the platform to create realistic-looking output. They can write a story that reads like it was written by Stephen King (but wasn’t) or pen a song that sounds like it was written by Taylor Swift (but wasn’t). But they can't do your legal research for you. ChatGPT does not access legal databases like Westlaw or Lexis, draft and input a query, review and analyze each of the results, determine which results are on point, and then compose an accurate, Bluebook-conforming citation to the right cases—all of which it would have to do to be a useful research assistant. Instead, these AI platforms look at legal briefs in their training model and then create output that looks like a legal brief by “placing one most-likely word after another” consistent with the prompt it received.

Kheir v. Titan Team, No. 25-bk-3033, slip op. at 5-6 (Bankr. S.D. Tex. Nov. 4, 2025), Dkt. No. 35

The increased use by lawyers and non-lawyers of artificial intelligence to draft legal documents has resulted in a scourge of fictitious case citations in court documents in recent years. Many harms flow from deceptively citing to nonexistent case law and fabricated quotations, “including wasting the opposing party's time and money, the Court's time and resources, and reputational harms to the legal system (to name a few).”

Mid-America Apartment Communities, Inc. v. Philipson, No. 23-cv-2186, 2025 WL 2625359, at *2 (W.D. Tenn. Sep. 11, 2025) (quoting Buckner v. Hilton Glob., No. 3:24-CV-375-RGJ, 2025 WL 1725426, at *7 (W.D. Ky. June 20, 2025) and Morgan v. Cmty. Against Violence, No. 23-CV-353-WPJ/JMR, 2023 WL 6976510, at *8 (D.N.M. Oct. 23, 2023))

Plaintiff has demonstrated no real intent to take heed of and abide by the Court's warnings. The threats she and her agent have made to opposing parties and counsel are outrageous, warranting the imposition of a terminating sanction. Moreover, her otherwise abusive litigation tactics and frivolous, unhinged filings compound the need for the most severe sanction of dismissal with prejudice. Any sanction short of dismissal might incentivize future litigants to similarly threaten violence against opposing parties and counsel, or submit excessive frivolous filings that contain fabricated legal authority and evidence. Moreover, because Plaintiff is proceeding in forma pauperis, the Court finds that a monetary sanction would be ineffective. Accordingly, dismissal with prejudice is the most appropriate sanction that would effectively cure the prejudice to Defendants, deter future misconduct, and punish Plaintiff for her wrongdoing.

Robinson v. Oglala Sioux Tribe, No. 25-cv-289, 2025 WL 2609573, at *7 (W.D. Okla. Sep. 9, 2025)

The errors addressed above are only a sampling. Taken together, they form a pattern that indicates Counsel may have used AI to generate filings without confirming the accuracy of authority relied upon, existence of evidence cited, or defensibility of positions taken. If AI was not used, these filings indicate wholesale inability to identify and marshal applicable law and a degree of sloppiness that severely impaired the briefs’ utility to [the plaintiff] and the Court.

Parker v. Costco Wholesale Corp., No. 25-cv-519, 2025 WL 2481280, at *4 (W.D. Wash. Aug. 28, 2025)

The legal profession has entered a brave new world of technological advances. Generative artificial intelligence (“AI”) has become increasingly accessible in recent years, making it easier than ever to quickly distill information from a plethora of sources. Many lawyers have embraced this technology, seeing it as a valuable tool to help them serve their clients in more efficient and cost-effective ways. As with other new developments in the practice of law, there are growing pains. Attorneys must reconcile the integration of new technology in their work with their existing ethical duties and professional responsibilities. Without proper knowledge of how AI works, lawyers may unjustifiably rely on the content it generates in ways that violate rules of professional responsibility.

In re Richburg, 671 B.R. 918, 919 (Bankr. D.S.C. 2025)

Courts exist to decide controversies fairly, in accordance with the law. This function is undermined when litigants using AI persistently misrepresent the law to the courts. AI is a powerful tool, that when used prudently, provides immense benefits. When used carelessly, it produces frustratingly realistic legal fiction that takes inordinately longer to respond to than to create. While one party can create a fake legal brief at the click of a button, the opposing party and court must parse through the case names, citations, and points of law to determine which parts, if any, are true. As AI continues to proliferate, this creation-response imbalance places significant strain on the judicial system.

Trials are a search for the truth. Parties who cite false cases not only seek to secure unfair advantage, they are, in fact, avatars of a post-truth world. Some people seem to believe that facts and truth no longer matter, but that is not how we do things in this Court. If the third branch of government in these United States cannot hold course and tack against the headwinds of foolishness and utter contempt for the truth daily poured into the body politic by strivers saluted by the fourth estate, then we are condemned to a: “Depressing view,” said K. “The lie made into the rule of the world.”

Ferris v. Amazon.com Servs. LLC, No. 24-cv-304, 2025 WL 1122235, at *1-2 (N.D. Miss. Apr. 16, 2025)  (quoting Franz Kafka, The Trial 147 (1925))

The pervasive misrepresentations of the law in [the co-defendant's] filings cannot be tolerated. It serves to make a mockery of the judicial process. It causes an enormous waste of judicial resources to try to find cited cases that do not exist and to determine whether a cited authority is relevant or binding, only to determine that most are neither.

In like fashion, [the co-defendant's] adversaries also must run to ground the nonexistent cases or address patently irrelevant ones. The adversaries must thus incur needless legal fees and expenses caused by [the co-defendant's] pervasive citations to nonexistent or irrelevant cases.

Powhatan Cnty. Sch. Bd. v. Skinger, No. 24-cv-874, 2025 WL 1559593, at *10 (E.D. Va. June 2, 2025)

This case should be a warning to lawyers that your pleadings, motions, responses, replies, and other papers filed with any Court must be first checked and then double-checked. There is no room in our court system for the submission of fake, hallucinated case citations, facts, or law. And it is entirely preventable by competent counsel who do their jobs properly and competently.

Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enters. LLC, No. 17-cv-81140, 2025 WL 1440351, at *7 (S.D. Fla. May 20, 2025)

It appears to this court that, having already caught a very large break by virtue of plaintiff having cited non-existent precedent in her qualified immunity briefing, [the defendant] would now shut off the one remaining avenue by which the nature of his actions in this case might come to light. In the court's view, this result would be contrary to basic considerations of justice and fairness, since a civil lawsuit is, once again, supposed to be a search for the truth. Moreover, while plaintiff is making specific representations regarding powerful video evidence in her favor, [the defendant] is relying upon motions to strike her briefing for being too long and filing highly unorthodox interlocutory appeals seeking to stop discovery from proceeding regarding her state law claims. Under these circumstances, it seems quite clear to this court which party to this litigation seems most afraid of an inquiry into the truth, and, for all her weaknesses as a litigant, that party is not plaintiff.

Newbern v. DeSoto Cnty. Sch. Dist., 782 F. Supp. 3d 329, 336 (N.D. Miss. 2025)

Artificial intelligence may ultimately prove a helpful tool to assist pro se litigants in bringing meritorious cases to the courts. In that way, artificial intelligence has the potential to contribute to the cause of justice. However, accessing any beneficial use of artificial intelligence requires carefully understanding its limitations. For example, if merely asked to write an opposition to an opposing party's motion or brief, or to respond to a court order, an artificial intelligence program is likely to generate such a response, regardless of whether the response actually has an arguable basis in the law. Where the court or opposing party was correct on the law, the program will very likely generate a response or brief that includes a false statement of the law. And because artificial intelligence synthesizes many sources with varying degrees of trustworthiness, reliance on artificial intelligence without independent verification renders litigants unable to represent to the Court that the information in ​​​​​​their filings is truthful.

Moales v. Land Rover Cherry Hill, No. 25-cv-544, 2025 WL 1249616, at *4 (D. Conn. Apr. 30, 2025)