A lawyer in California was hit with sanctions by the courts after it was discovered that he had been citing cases that did not exist — and that were completely made up by artificial intelligence (AI) programs.
The Daily Journal reported:
By now, most attorneys are familiar with the limitations of artificial intelligence–particularly its tendency to produce fabricated citations and unreliable authority–but the California Court of Appeal has now made clear that those “hallucinations” can carry very real consequences.
In Noland v. Land of the Free, L.P. (B331918, Sept. 12, 2025), Division Three of the Second District sanctioned the plaintiff/appellant’s attorney $10,000 and reported him to the state bar after finding that nearly all of the legal quotations in his appellate briefs were invented by generative AI tools and had never appeared in any published case.
And the Court was clear as to the reasons why it was publishing the opinion: “We … publish this opinion as a warning. Simply stated, no brief, pleading, motion, or any other paper filed in any court should contain any citations–whether provided by generative AI or any other source–that the attorney responsible for submitting the pleading has not personally read and verified.” (emphasis in original).
In addition to fake cases, AI sometimes imagines fake events. Recently, ChatGPT accused legal scholar and Fox News contributor Jonathan Turley of sexual harassment by a student — but it never happened — neither the harassment nor the accusation.
Joel B. Pollak is Senior Editor-at-Large at Breitbart News and the host of Breitbart News Sunday on Sirius XM Patriot on Sunday evenings from 7 p.m. to 10 p.m. ET (4 p.m. to 7 p.m. PT). He is the author of The Zionist Conspiracy Wants You, now available on Amazon. He is a winner of the 2018 Robert Novak Journalism Alumni Fellowship. Follow him on Twitter at @joelpollak.
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