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Lawyers Continue to Get in Hot Water For Citing AI Hallucinated Cases
Friday, June 20, 2025

We have previously outlined several cases where lawyers have been sanctioned by courts for citing fake cases generated by artificial intelligence (AI), also known as “hallucinations.”

Now, we don’t even have to keep track of the cases to report on them because we found a nifty new database that keeps track of all of them. Did you know that as of this writing, there have been 156 cases where lawyers cited fake cases generated by AI in court documents?

It is hard to believe that with Rule 11 obligations, any lawyer would file a document with a court without checking the cite. Apparently, it happens more frequently than one would think. Many lawyers have already been sanctioned by courts to send the message that citing fake cases generated by AI is a waste of the court’s time, as well as a waste of the time and resources of opposing counsel and parties.

Kudos to Damien Charlotin, who has created a database to track the growing number of cases where lawyers have cited AI generated hallucinated cases. If you want to see how it is a growing problem, check it out.

The cases grow, and the sanctions continue to get larger and more punitive. Lawyers need to quickly learn that they must follow their ethical obligations and provide actual cases, with citations checked and shepardized with human oversight, before filing a pleading. It is truly shocking that lawyers have failed to do so in 156 instances thus far.

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