{"meta":{"exportedAt":"2026-11-07T02:56:07.103Z","formatVersion":2,"selection":{"q":"fabricated-citations","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"2023","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":1,"languages":1,"unknownLocation":1,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":2,"minors":0,"coreRelations":2,"contextualRelations":1,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2023-new-york-federal-judge-sanctions-lawyers-over-chatgpt-invented-cases-chatbot-said-were-real","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'March 1, 2023 submission that first cited the fake cases'; 'On March 1, 2023, Mr. LoDuca filed an “Affirmation in Opposition” to'; 'citing non-existent cases to the Court in his Affirmation in Opposition'","relation":"supports","source_id":"s1"},{"locator":"'The original case involved a man suing an airline over an alleged personal injury.'","relation":"supports","source_id":"s2"}],"assertion":"An affirmation in opposition filed on 1 March 2023 in a personal-injury suit against Avianca cited judicial decisions that did not exist.","causal_attribution":"Established by the court record; BBC reports the nature of the suit."},{"id":"c2","status":"documented","evidence":[{"locator":"'Mr. Schwartz had used ChatGPT, which'; 'fabricated the cited cases.'","relation":"supports","source_id":"s1"},{"locator":"used ChatGPT to look for similar previous cases.","relation":"supports","source_id":"s2"}],"assertion":"The court found that the lawyer who researched the brief had used ChatGPT and that ChatGPT fabricated the cited cases.","causal_attribution":"Finding of the sanctions opinion, based on the lawyer's own testimony and filings; BBC reports his written statement."},{"id":"c3","status":"documented","evidence":[{"locator":"'“Is Varghese a real case” and “Are the other cases you provided fake”). (ECF 32-1.) ChatGPT'; 'responded that it had supplied “real” authorities that could be found through Westlaw,'","relation":"supports","source_id":"s1"},{"locator":"ChatGPT responds again that the case is real and can be found on legal reference databases such as LexisNexis and Westlaw.","relation":"supports","source_id":"s2"}],"assertion":"When the lawyer asked ChatGPT whether Varghese was a real case and whether the other cases were fake, ChatGPT replied that it had supplied real authorities that could be found on legal databases.","causal_attribution":"The opinion describes the screenshots the lawyer filed (ECF 32-1); the exhibit itself was not read."},{"id":"c4","status":"documented","evidence":[{"locator":"'the Court finds bad faith on the part of the individual Respondents based upon acts of'; 'A penalty of $5,000 is jointly and severally imposed on'; 'mail a letter individually addressed to plaintiff'; 'mail a letter individually addressed to each judge falsely identified as the author of the fake'","relation":"supports","source_id":"s1"}],"assertion":"On 22 June 2023 the court found bad faith by both individual lawyers, imposed a USD 5,000 penalty jointly and severally on them and their firm, and ordered letters to the client and to each judge falsely identified as an author of the fake opinions.","causal_attribution":"Established by the sanctions opinion itself."},{"id":"c5","status":"documented","evidence":[{"locator":"'nothing inherently improper about using a reliable artificial intelligence tool for assistance. But'; 'then continued to stand by the fake opinions'","relation":"supports","source_id":"s1"}],"assertion":"The court said that using a reliable AI tool is not inherently improper and based the sanctions on the lawyers continuing to stand by the fake opinions after the court questioned them.","causal_attribution":"Context and contrary weight: the sanction responds to the lawyers' conduct as well as to the AI output."}],"effects":[{"label":"two lawyers were found to have acted in bad faith and sanctioned over ChatGPT-invented case law","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.575368/gov.uscourts.nysd.575368.54.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-28 from the RECAP copy of the 43-page opinion (HTTP 200, text extracted with pdftotext). The hearing transcript, the April and May affidavits and the screenshot exhibit (ECF 32-1) were not read separately.","independence_group":"sdny-avianca-sanctions-opinion"},{"id":"s2","url":"https://www.bbc.com/news/world-us-canada-65735769","kind":"news_report","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-28 (HTTP 200). BBC reports the filings before the sanctions hearing.","independence_group":"bbc-avianca-chatgpt-lawyer"}],"version":1,"ai_roles":["own_use","others_use"],"contexts":["justice","work"],"unknowns":["Whether any professional disciplinary body later acted against either lawyer, and whether the sanctions were appealed, was not checked in this review.","Which ChatGPT version was used; the opinion records the lawyer's prompts and the chatbot's responses only as summarised from exhibits.","Whether the fake citations affected the plaintiff's own claim; the separate ruling on the airline's motion to dismiss was not read."],"geography":{"basis":"The brief was filed in, and the sanctions imposed by, the US District Court for the Southern District of New York (sanctions opinion). Where the lawyer ran his ChatGPT queries is not stated, so no event or affected-person country is recorded from the court seat.","court_countries":["US"],"event_countries":[],"affected_person_countries":[]},"publication":{"basis":"Published because the federal sanctions opinion of 22 June 2023 documents that ChatGPT fabricated the cases cited in a filed brief, that it told the lawyer who used it the cases were real, and that the court sanctioned two lawyers and their firm after finding bad faith.","reviewed_on":"2026-10-28"},"ai_involvement":{"basis":"The sanctions opinion finds that the lawyer who researched the brief used ChatGPT, which fabricated the cited cases, and records from his filed screenshots that when he asked whether Varghese was a real case and whether the other cases were fake, ChatGPT replied that it had supplied real authorities findable on Westlaw, LexisNexis and the Federal Reporter. The fabricated authorities reached the court in the 1 March 2023 filing; the court read them, found them fake and sanctioned the two lawyers (communicated_with for the lawyer who used ChatGPT; informed_decision_about because the court's sanctions decision acted on the AI-invented authorities). The court based its bad-faith finding on the lawyers' conduct after the citations were questioned.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"New York federal judge sanctions two lawyers whose brief cited cases ChatGPT invented, after the chatbot told one of them the cases were real (2023)","summary":"In a passenger's personal-injury suit against the airline Avianca in the US District Court for the Southern District of New York, an opposition brief filed on 1 March 2023 cited judicial opinions that did not exist. The court found that the lawyer who did the research had used ChatGPT, which fabricated the cases, and that when he asked the chatbot whether one of them was real it replied that it had supplied real authorities that could be found on legal databases. On 22 June 2023 the court found bad faith by the two lawyers, based on their conduct after the citations were questioned, and imposed a USD 5,000 penalty jointly on them and their firm, together with letters to the client and to each judge falsely named as an author of the fake opinions.","incidentDate":"2023-03-01","incidentEndDate":"2023-06-22","incidentKind":"bounded_series","incidentDatePrecision":"day","exposurePattern":"repeated_interactions","reportedDate":"2023-05-27","aiSystem":"ChatGPT, which the court found the researching lawyer used and which fabricated the cited cases","aiProduct":"ChatGPT","aiCompany":"OpenAI","severity":"medium","verificationStatus":"verified","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm","financial_loss"],"harmOutcomeSummary":"According to the court's sanctions opinion of 22 June 2023, two lawyers were found to have acted in bad faith and, with their firm, were ordered to pay a USD 5,000 penalty and to write to the client and to the judges falsely named as authors of the ChatGPT-invented opinions.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"Two lawyers sanctioned in the 22 June 2023 opinion: the lawyer the court found used ChatGPT (counted as the AI user) and the attorney of record who filed the brief. The firm is not counted as a person.","victimAgeRange":"adult","jurisdiction":"US","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.575368/gov.uscourts.nysd.575368.54.0.pdf","primarySourceLabel":"US District Court for the Southern District of New York, No. 1:22-cv-01461-PKC, Opinion and Order on Sanctions (ECF 54), 22 June 2023","firstPublishedAt":"2026-10-28T03:16:40.650766+00:00","updatedAt":"2026-10-28T03:16:40.650766+00:00","scopeVersion":"facts-v3","tags":["chatgpt","fabricated-citations","federal-court","sanctions","lawyers","new-york"]},{"id":"2023-colorado-lawyer-suspended-after-motion-cited-fictitious-cases-from-chatgpt-and-he-blamed-an-intern","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"'cited case law that he found through the artificial intelligence platform, ChatGPT'; 'discovered that the cases from ChatGPT were either incorrect or fictitious'","relation":"supports","source_id":"s1"},{"locator":"'The motion cited three cases to support'; 'that were made up by the generative AI program, which the lawyer didn’t realize until it was too late.'","relation":"supports","source_id":"s2"}],"assertion":"The lawyer cited case law found through ChatGPT in a client's motion to set aside a judgment without reading or verifying it, and the cited cases were incorrect or fictitious; Law Week Colorado reports three non-existent Court of Appeals decisions.","causal_attribution":"The disciplinary summary attributes the fictitious citations to ChatGPT; the lawyer's affidavit says the same."},{"id":"c2","status":"reported","evidence":[{"locator":"'falsely attributed the mistakes to a legal intern'; 'Six days after the hearing'; 'did not alert the court to the sham cases at the hearing. Nor did he withdraw the motion.'","relation":"supports","source_id":"s1"},{"locator":"'I think all my cases cited from chatGPT are garbage'; 'the morning he was set to appear in front of the court May 5'","relation":"supports","source_id":"s2"}],"assertion":"On the morning of the hearing the lawyer realised the ChatGPT citations were fabricated, did not alert the court or withdraw the motion, and falsely attributed the mistakes to a legal intern; six days later he filed an affidavit saying he had used ChatGPT.","causal_attribution":"Findings in the stipulated disciplinary summary and the lawyer's own filed messages."},{"id":"c3","status":"reported","evidence":[{"locator":"'denied the motion and ordered'; 'his decision to deny the motion wasn’t based on the made-up cases'","relation":"supports","source_id":"s2"}],"assertion":"The judge denied the motion, ordered the lawyer to explain why he should not be sanctioned and reported to attorney regulators, and later stated that the denial was not based on the made-up cases.","causal_attribution":"Law Week Colorado's report of the court's orders."},{"id":"c4","status":"reported","evidence":[{"locator":"'for one year and one day, with ninety'; 'The suspension took effect November 22, 2023.'","relation":"supports","source_id":"s1"},{"locator":"'with 90 days to be served and the remainder to be stayed upon'","relation":"supports","source_id":"s3"}],"assertion":"The Presiding Disciplinary Judge approved a stipulation suspending the lawyer for one year and one day, with 90 days served and the remainder stayed on two years of probation, effective 22 November 2023.","causal_attribution":"The disciplinary summary and its relay; one origin."},{"id":"c5","status":"reported","evidence":[{"locator":"'it never even dawned on me that this technology could be deceptive'; 'he was “overwhelmingly impressed” by ChatGPT’s capabilities after the program gave him accurate responses to a number of questions he asked as a test'","relation":"supports","source_id":"s2"}],"assertion":"In his affidavit the lawyer said earlier accurate answers from ChatGPT had made him trust its case citations.","causal_attribution":"The lawyer's own account in his affidavit, as quoted by Law Week Colorado."}],"effects":[{"label":"motion cited three fictitious cases supplied by ChatGPT","claim_id":"c1","direction":"negative"},{"label":"lawyer suspended for one year and one day, 90 days served","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.cobar.org/Portals/COBAR/Repository/Family%20Law%20Section%20Folder/AI%20EXHIBITS%20-%20Combined.pdf","kind":"court_record_reproduction","access":"read","language":"en","translation_note":"Read in English on 2026-10-26 from an Internet Archive capture of the Colorado Bar Association PDF (the live file returned HTTP 403); page 1 reproduces the Presiding Disciplinary Judge's summary of 23PDJ067.","independence_group":"colorado-pdj-23pdj067-summary"},{"id":"s2","url":"https://www.lawweekcolorado.com/article/colorado-lawyer-cited-fake-cases-in-motion-written-with-chatgpt/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English on 2026-10-26 (HTTP 200, full article body).","independence_group":"lawweek-colorado-2023-06-21"},{"id":"s3","url":"https://www.lawweekcolorado.com/article/court-opinions-presiding-disciplinary-judge-opinions-for-oct-31-nov-22/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English on 2026-10-26 (HTTP 200); relays the disciplinary opinion, so it shares s1's independence group.","independence_group":"colorado-pdj-23pdj067-summary"}],"version":1,"ai_roles":["own_use"],"contexts":["work","justice"],"unknowns":["Whether the lawyer's employment with his firm ended because of the motion; the firm did not answer Law Week Colorado's questions.","Which version of ChatGPT was used.","The full stipulation and opinion text beyond the published summary."],"geography":{"basis":"The motion was filed in a Colorado district court by a lawyer working in his firm's Colorado Springs office (Law Week Colorado), and the discipline was imposed by Colorado's Presiding Disciplinary Judge.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":["US"]},"publication":{"basis":"Published because ChatGPT supplied fictitious case citations that a lawyer filed unchecked, and Colorado's Presiding Disciplinary Judge suspended him, with the misconduct findings including his false statement blaming an intern. The disciplinary summary records the ChatGPT use and the sanction.","reviewed_on":"2026-10-26"},"ai_involvement":{"basis":"The Presiding Disciplinary Judge's summary records that the lawyer cited case law he found through ChatGPT, that the cases were incorrect or fictitious, and that he later filed an affidavit saying he used ChatGPT; Law Week Colorado reports from the affidavit that ChatGPT supplied three non-existent appellate decisions. The fabricated citations, together with his failure to check them and his false statement about an intern, led to the suspension.","status":"supported"},"person_relations":["communicated_with"]},"name":"Colorado lawyer suspended for a year and a day, 90 days served, after filing a motion with fictitious ChatGPT case citations and blaming an intern","summary":"A Colorado lawyer who had recently moved into civil litigation used ChatGPT in April and May 2023 to find case law for a client's motion to set aside a judgment and cited three Colorado Court of Appeals decisions that did not exist, without reading or checking them. On the morning of the 5 May hearing he realised the cases were fabricated but did not tell the court or withdraw the motion, and when the judge raised concerns he falsely blamed a legal intern; six days later he filed an affidavit saying he had used ChatGPT. The judge denied the motion, said the denial did not rest on the invented cases, and ordered him to show cause why he should not be sanctioned and reported to attorney regulators. On 22 November 2023 Colorado's Presiding Disciplinary Judge approved a stipulation suspending him for one year and one day, with 90 days served and the rest stayed on two years' probation, for violating rules on competence, diligence, candour to the tribunal and honesty.","incidentDate":"2023-05-01","incidentKind":"single_event","incidentDatePrecision":"month","exposurePattern":"repeated_interactions","reportedDate":"2023-06-21","aiSystem":"ChatGPT, which the lawyer used to find case law for the motion and which supplied three citations to decisions that did not exist","aiProduct":"ChatGPT","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","legal_harm"],"harmOutcomeSummary":"A lawyer who relied on unchecked ChatGPT case citations, then misled the court about them, was suspended from practice for a year and a day, with 90 days served, by Colorado's Presiding Disciplinary Judge.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the lawyer, who used ChatGPT himself and was suspended. The client's motion was denied, but the judge stated the denial did not rest on the fabricated cases, so no harm to the client is counted.","victimAgeRange":"adult","jurisdiction":"US-CO","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.cobar.org/Portals/COBAR/Repository/Family%20Law%20Section%20Folder/AI%20EXHIBITS%20-%20Combined.pdf","primarySourceLabel":"Colorado Bar Association exhibit reproducing the Presiding Disciplinary Judge's summary, 23PDJ067, 22 November 2023","firstPublishedAt":"2026-10-26T03:14:58.604934+00:00","updatedAt":"2026-10-26T03:14:58.604934+00:00","scopeVersion":"facts-v3","tags":["legal","lawyer","chatgpt","fabricated-citations","professional-discipline","own-use","work"]}]}