AI may have struck again with hallucinations. Yesterday evening, I was forwarded a quote from the case opinion of Shahid v. Esaam, 2025 Ga. App. LEXIS 299, at *3 [Ct App June 30, 2025, No. A25A0196]) released on June 30, 2025 by the Georgia Court of Appeals. (HT Mary Matuszak!)(link to official opinion, not Lexis):
We are troubled by the citation of bogus cases in the trial court’s order. As the reviewing court, we make no findings of fact as to how this impropriety occurred, observing only that the order purports to have been prepared by Husband’s attorney, Diana Lynch. We further note that Lynch had cited the two fictitious cases that made it into the trial court’s order in Husband’s response to the petition to reopen, and she cited additional fake cases both in that Response and in the Appellee’s Brief filed in this Court.
Background
The Georgia Court of Appeals (CoA) heard an appeal to reopen a divorce case in the Superior Court of Dekalb County, GA. The Appellant brought to the attention of the CoA that the “trial court relied on two fictitious cases in its order denying her petition.” The Appellee’s attorney ignored this claim and went on to argue the original argument of proper service by publication with multiple fictitious and misrepresented cases. The Appellee’s attorney also demanded attorney’s fees based on another fictitious case that claimed the exact opposite of existing case law. In total, the CoA provided this breakdown of the inaccuracy rate of the citations provided by the Appellant’s attorney, “73 percent of the 15 citations in the brief or 83 percent if the two bogus citations in the superior court’s opinion and the five additional bogus citations in Husband’s response to Wife’s petition to reopen Case are included.” The distraught CoA struck the lower court order, remanded the case, and sanctioned the Appellee’s attorney.
Digging into the Case
I was curious about all of this, so I did some digging this morning. I am still working on acquiring the CoA briefs, but I was able to access the documents from the trial court. The CoA was very cognizant that they do not have any actual proof at this time that AI was used, but with the number of bad citations that the Appellant’s attorney submitted, the CoA speculated about the use of a consumer AI model in the footnotes. To test this theory, I decided not only to do some reading, but to test out LawDroid’s new CiteCheck AI tool. Spoiler alert: I think the speculations are accurate.
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