J Michael Dockery just published this to linked in
Another week, another lawyer in trouble for AI hallucinations – the judge here calls out that “nearly half the pages” in this attorney’s brief contained hallucinated citations.
The court provides an interesting sampling of the errors that were found, starting on page 10.
Some of the hallucinations were deceptive in a weirdly clever way – for example, pulling relevant quotes from non-binding cases, and then changing the citations so that they appear to be quotes from binding authority. Others were just typical AI garbage – garbled citation information and citations that don’t actually support the proposition for which they are being cited.
The judge makes clear that it’s the substance that’s at issue here – noting that citation mistakes that merely make materials more difficult to find aren’t major concerns, and that the court is “not generally in the business of quibbling with a party’s citations.”
But the court is clearly very concerned about the lack of proper review, stating its concerns that “the brief was not properly reviewed for accuracy and may have been prepared using GAI without proper review.” For this reason, the court issued a show cause.
[pdf-embedder url=”https://practicesource.com/wp-content/uploads/2025/10/1759413358986.pdf”]
