{"meta":{"exportedAt":"2026-11-14T10:48:26.032Z","formatVersion":2,"selection":{"q":"hallucinated-citations","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"2026","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":5,"coverage":{"cases":5,"countries":2,"languages":2,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":4,"minors":0,"coreRelations":5,"contextualRelations":3,"mixedRelations":3,"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":"2026-arizona-appeals-court-strikes-self-represented-appellants-ai-hallucinated-citations-orders-fees-sanction","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"In his opening brief with the Court of Appeals, he made eight citations. The court found that six of them were deficient; two were cases that “simply do not exist.”","relation":"supports","source_id":"s1"}],"assertion":"The self-represented appellant's opening brief made eight citations; the court found six deficient, including two cases that do not exist.","causal_attribution":"The court's findings as reported by the Arizona Mirror."},{"id":"c2","status":"reported","evidence":[{"locator":"readily acknowledged that he relied on generative AI to write his brief; he admitted he did nothing to independently verify the citations","relation":"supports","source_id":"s1"}],"assertion":"In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and admitted doing nothing to verify the citations.","causal_attribution":"The appellant's own acknowledgement, recorded in the opinion and reported by the Arizona Mirror."},{"id":"c3","status":"reported","evidence":[{"locator":"Accordingly, citing a hallucinated case in a legal filing is sanctionable conduct; traceable to dealing with the fake citations; appeal was also rejected because there were no supportive legal authorities for his claims once the inaccurate and false citations were stricken","relation":"supports","source_id":"s1"}],"assertion":"The court held that citing a hallucinated case is sanctionable regardless of intent, ordered him to pay the portion of the other party's attorney's fees traceable to the fake citations, and rejected the appeal because no supportive authority remained once the citations were struck.","causal_attribution":"The court's ruling as reported."},{"id":"c4","status":"reported","evidence":[{"locator":"The three-judge panel noted that court rules allow for more severe sanctions, including contempt charges and monetary fines.; isn’t a trained legal professional, it opted to narrowly sanction him","relation":"supports","source_id":"s1"}],"assertion":"The court chose this narrow sanction over contempt or fines because he said he did not intend to deceive and is not a trained legal professional.","causal_attribution":"The court's reasoning as reported."}],"effects":[{"label":"brief citations struck, appeal rejected and fee sanction ordered","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","kind":"news","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-18 (HTTP 200); no translation was needed. Republication of the Arizona Mirror (States Newsroom) report.","independence_group":"arizona-mirror-report-jul-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice"],"unknowns":["Which generative AI tool the appellant used.","The amount of the fee award, which depended on the other party's documentation."],"geography":{"basis":"The brief was filed in, and the sanction imposed by, the Arizona Court of Appeals in a Maricopa County probate appeal. Residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published on the Arizona Mirror's report of the Court of Appeals opinion of 15 July 2026: a self-represented appellant acknowledged relying on generative AI to write a brief that cited nonexistent cases, and the court struck the citations, rejected the appeal and ordered him to pay the fees they caused. The parties are private persons and are not named.","reviewed_on":"2026-10-18"},"ai_involvement":{"basis":"The appellant acknowledged in a written explanation and at a hearing on the false citations that he relied on generative AI to write his opening brief, which the court found cited two nonexistent cases and misstated others; the AI-generated text reached him (communicated_with), and the court read the fabricated citations, struck them, rejected the appeal for want of authority and imposed a fee sanction for them (informed_decision_about). The tool is not named.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Arizona appeals court strikes a self-represented appellant's AI-hallucinated citations, rejects his probate appeal and orders him to pay fees as a sanction","summary":"In a published opinion of July 2026, the Arizona Court of Appeals found that a self-represented appellant's opening brief in a probate dispute contained eight citations, six of them deficient, including two cases that do not exist. In a written explanation and at a hearing on the false citations he acknowledged relying on generative AI to write the brief and said he did nothing to verify the citations. The court struck the inaccurate and false citations, rejected the appeal because no supportive authority remained, held that citing a hallucinated case is sanctionable whether or not it is intended, and ordered him to pay the share of the other party's attorney's fees traceable to the fake citations. Because he said he did not intend to deceive and is not legally trained, the court chose this narrow sanction over contempt or fines. It described the opinion as the first published Arizona ruling on generative AI hallucinations in filings.","incidentDate":"2026-07-15","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-07-19","aiSystem":"Generative AI, not identified in the report, that the appellant said he relied on to write his opening brief, which cited two nonexistent cases and misstated others","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","financial_loss"],"harmOutcomeSummary":"According to the court, the appellant's AI-drafted brief cited nonexistent cases; the citations were struck, the appeal was rejected and he was ordered to pay the share of the other party's attorney's fees caused by the fake citations.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the self-represented appellant who used generative AI and was sanctioned.","victimAgeRange":"adult","jurisdiction":"US-AZ","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://kiowacountypress.net/content/arizona-court-appeals-citing-fake-ai-generated-cases-can-get-you-sanctioned-no-matter-your","primarySourceLabel":"Arizona Mirror (States Newsroom), republished by Kiowa County Press, July 2026: Arizona Court of Appeals on sanctions for fake AI-generated cases","firstPublishedAt":"2026-10-18T03:14:48.762612+00:00","updatedAt":"2026-10-18T03:14:48.762612+00:00","scopeVersion":"facts-v3","tags":["hallucinated-citations","self-represented-litigant","appeal","sanction","attorney-fees","arizona"]},{"id":"2026-los-angeles-court-sanctions-state-farm-outside-lawyer-for-motions-citing-non-existent-cases-from-ai-tool","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"An attorney for State Farm who filed several motions citing nonexistent cases and fabricated quotes generated by AI software must pay a $999.99 sanction, a Los Angeles judge ruled","relation":"supports","source_id":"s1"}],"assertion":"A Los Angeles judge ordered the State Farm attorney who filed several motions citing non-existent cases and fabricated quotations generated by AI software to pay a $999.99 sanction.","causal_attribution":"Law360's report of the order; the order itself was not inspected."},{"id":"c2","status":"reported","evidence":[{"locator":"To assist in my preparation of these motions, I utilized an Artificial Intelligence program called \"Irys.\" However, I regrettably did not check some of the cites I chose to include in the filed pleadings ... there were seven (7) case citations across State Farm's eight (8) motions in limine that simply did not exist","relation":"supports","source_id":"s2"},{"locator":"used an AI tool called Irys, which she incorrectly thought was tied to her law firm","relation":"supports","source_id":"s3"}],"assertion":"In a declaration, the associate who prepared the motions said she used an AI program called Irys to prepare them, did not check some of the citations because she wrongly believed the program was cite-checked through the firm's Westlaw subscription, and confirmed seven case citations across eight motions in limine that did not exist.","causal_attribution":"The associate's own declaration (reproduced by Reason and summarised by CalMatters); one origin."},{"id":"c3","status":"corroborated","evidence":[{"locator":"informed the Court that they had discovered several citations in State Farm's motion in limine filings that were \"fabricated\" and possibly \"hallucinations.\"","relation":"supports","source_id":"s2"},{"locator":"were brought to the court's attention during a status hearing on Aug. 7","relation":"supports","source_id":"s1"},{"locator":"shared his findings at an Aug. 7 conference in Los Angeles Superior Court","relation":"supports","source_id":"s3"}],"assertion":"The plaintiff's lawyers found the non-existent citations and raised them with the court at a status conference on 7 August 2026.","causal_attribution":"The associate's declaration and the plaintiff side's own filings (as reported by Law360 and CalMatters) agree on the discovery and its date."},{"id":"c4","status":"reported","evidence":[{"locator":"he had discovered seven made-up cases, nine quotes for orders that did not exist and 13","relation":"supports","source_id":"s1"}],"assertion":"According to a declaration by one of the plaintiff's lawyers, the filings contained seven made-up cases, nine quotations from orders that did not exist and 13 fabricated holdings or statements of law.","causal_attribution":"The plaintiff lawyer's declaration as reported by Law360."},{"id":"c5","status":"reported","evidence":[{"locator":"acknowledged the firm had discovered “nonexistent case citations which appear to have been AI hallucinations” across a recent batch of motions","relation":"supports","source_id":"s4"},{"locator":"apologized to the court and to the plaintiff, explaining that his co-counsel told him she used AI to help prepare some filings","relation":"supports","source_id":"s3"}],"assertion":"The firm acknowledged citations that appeared to be AI hallucinations, and its lead trial counsel apologised to the court and to the plaintiff, saying his co-counsel told him she had used AI to help prepare some filings.","causal_attribution":"The firm's own filings, as reported by the Los Angeles Times and CalMatters."},{"id":"c6","status":"reported","evidence":[{"locator":"particularly as it relates to State Farm's first five motions in limine which our office filed and served on March 31, 2026","relation":"supports","source_id":"s2"}],"assertion":"The associate's declaration ties the issue particularly to the first five motions in limine, which the firm filed and served on 31 March 2026.","causal_attribution":"The associate's declaration."},{"id":"c7","status":"reported","evidence":[{"locator":"The sum falls several thousand dollars below the maximum penalty, $5,000, that Judge Bradley said she was considering when setting the sanctions hearing","relation":"supports","source_id":"s1"}],"assertion":"According to Law360, the judge had said in late August that she was considering a sanction of up to $5,000; the $999.99 set is one cent below the level that requires a California court to notify the State Bar.","causal_attribution":"Law360's report of the two orders."},{"id":"c8","status":"reported","evidence":[{"locator":"State Farm expects its external counsel to conform to the highest level of ethical standards and professionalism, including in their use of AI and confirming the accuracy of all legal filings","relation":"supports","source_id":"s4"}],"assertion":"State Farm said it expects its outside counsel to meet the highest ethical and professional standards, including in their use of AI and in confirming the accuracy of filings.","causal_attribution":"State Farm spokesperson's statement to the Los Angeles Times."},{"id":"c9","status":"reported","evidence":[{"locator":"I am sincerely apologetic for the inconvenience and waste of time and resources I have forced the Court","relation":"supports","source_id":"s2"}],"assertion":"The associate's declaration apologised for the time and resources the court, the plaintiff and the attorneys had to spend on the issue.","causal_attribution":"The associate's declaration."}],"effects":[{"label":"sanctioned $999.99 for motions with non-existent citations prepared with an AI program","claim_id":"c1","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.law360.com/articles/2524716/state-farm-attorney-sanctioned-999-99-for-ai-hallucinations","kind":"news","access":"read","language":"en","translation_note":"Read in full on 2026-10-17 (HTTP 200). Published 14 September 2026; reports the sanction order, the late-August order and the plaintiff lawyer's declaration.","independence_group":"law360-report-of-sanction-order-september-2026"},{"id":"s2","url":"https://reason.com/volokh/2026/08/24/ai-hallucinations-in-state-farm-insurance-outside-lawyers-filings/","kind":"commentary_with_filing_excerpt","access":"read","language":"en","translation_note":"Read on 2026-10-17 (HTTP 200). Published 24 August 2026; reproduces long passages of the associate's declaration and quotes the Los Angeles Times.","independence_group":"state-farm-associate-declaration-august-2026"},{"id":"s3","url":"https://calmatters.org/economy/2026/08/state-farm-lawsuit-ai-hallucinations/","kind":"news","access":"read","language":"en","translation_note":"Read on 2026-10-17 through an Internet Archive capture after the live page returned HTTP 429. Published 18 August 2026; reports filings by both sides.","independence_group":"calmatters-filings-report-august-2026"},{"id":"s4","url":"https://www.latimes.com/california/story/2026-08-19/ai-hallucinations-case-law-state-farm-la-county-fire-dispute","kind":"news","access":"read","language":"en","translation_note":"Read on 2026-10-17 (HTTP 200). Published 19 August 2026.","independence_group":"los-angeles-times-report-august-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["The text of the sanction order (not inspected; known through Law360).","Which citations Irys generated and which the associate wrote; the sources give only the totals.","Whether the false citations affected any ruling on the motions in limine; no source says so.","Whether the plaintiff incurred costs beyond the time spent identifying the citations; no source quantifies it."],"geography":{"basis":"The motions were filed in, and the sanction imposed by, Los Angeles County Superior Court in California. Where the associate lives is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published as a concrete adverse consequence of AI use: the associate's declaration says the AI program Irys was used to prepare motions that contained seven non-existent case citations, and the court sanctioned the associate $999.99 for them, according to Law360's report of the order.","reviewed_on":"2026-10-17"},"ai_involvement":{"basis":"The associate's declaration says she used the AI program Irys to prepare the motions and did not check some of the citations included in them; her review found seven non-existent case citations across eight motions, and the firm acknowledged citations that appeared to be AI hallucinations. The program's output reached the associate and went into the filings (communicated_with), and the court sanctioned the associate for them, Law360 reports. The tool's output itself is not reproduced in the inspected sources.","status":"supported"},"person_relations":["communicated_with"]},"name":"Los Angeles judge sanctions State Farm's outside lawyer $999.99 over motions citing non-existent cases; the lawyer said she prepared them with the AI tool Irys","summary":"A Los Angeles County Superior Court judge ordered a senior associate at Musick, Peeler & Garrett, the outside firm defending State Farm in a homeowner's lawsuit over a fire-damaged home, to pay a $999.99 sanction after the associate's motions in limine cited cases, quotations and holdings that did not exist, Law360 reported on 14 September 2026. In a declaration reproduced by Reason's Volokh Conspiracy, the associate said she used an AI program called Irys to prepare the motions, did not check some of the citations, and wrongly believed the program was cite-checked through the firm's Westlaw subscription; she confirmed seven non-existent case citations across eight motions. The plaintiff's lawyers found the citations and raised them at a status conference on 7 August 2026. The firm acknowledged citations that appeared to be AI hallucinations, and its lead trial counsel apologised to the court and the plaintiff. According to Law360, the judge had considered up to $5,000, and the amount set is one cent below the level at which California law requires a court to notify the State Bar.","incidentDate":"2026-03-31","incidentEndDate":"2026-09-11","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-08-18","aiSystem":"Irys, an AI legal research program that the lawyer told the court she used to prepare the motions; Law360 says it appears to be the tool built by Iqidis Inc.","aiProduct":"Irys (reported)","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["financial_loss","legal_harm"],"harmOutcomeSummary":"According to Law360's report of the order, the associate who filed the AI-assisted motions was sanctioned $999.99; the associate's declaration apologised for the time and resources the court, the plaintiff and the attorneys spent on the false citations.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the associate the court sanctioned (Law360). The associate's declaration apologises for time and resources that the court, the plaintiff and the attorneys spent on the issue; no further consequence for the plaintiff is described, so the plaintiff is not counted.","victimAgeRange":"adult","jurisdiction":"US-CA","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.law360.com/articles/2524716/state-farm-attorney-sanctioned-999-99-for-ai-hallucinations","primarySourceLabel":"Law360, State Farm Attorney Sanctioned $999.99 For AI Hallucinations (14 September 2026)","firstPublishedAt":"2026-10-17T03:02:07.57541+00:00","updatedAt":"2026-10-17T03:02:07.57541+00:00","scopeVersion":"facts-v3","tags":["united-states","california","legal-profession","hallucinated-citations","court-sanction","insurance-litigation"]},{"id":"2026-canary-islands-high-court-fines-lawyer-for-appeal-citing-48-false-judgments-generated-by-ai","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"ha impuesto una multa de 420 euros a un abogado como autor de una actuación contraria al deber de veracidad y a las reglas de la buena fe con abuso del servicio público de la Justicia, consumada al introducir hasta 48 citas de jurisprudencia falsas, generadas por Inteligencia Artificial, en un recurso de apelación; el Tribunal acuerda dar traslado de su decisión y de los antecedentes al Colegio de Abogados del afectado","relation":"supports","source_id":"s1"}],"assertion":"The Criminal Chamber of the TSJC fined a lawyer 420 euros for conduct contrary to the duty of truthfulness and good faith, committed by inserting up to 48 false case-law citations generated by AI into an appeal, and sent its decision to the lawyer's bar association for possible disciplinary action.","causal_attribution":"The court's own release on its order."},{"id":"c2","status":"documented","evidence":[{"locator":"se valió de una herramienta de Inteligencia Artificial “generalista” -es decir, no de una solución específicamente diseñada en el ámbito jurídico- para introducir en la fundamentación hasta 48 citas de sentencias del Tribunal Supremo y un informe del Consejo General del Poder Judicial que supuestamente avalaban su postura en el pleito y que, en realidad, no existían, según verificó la documentalista del TSJC; no verificó los datos de salida de la herramienta de IA con las bases de datos de jurisprudencia","relation":"supports","source_id":"s1"}],"assertion":"According to the order, the lawyer used a general-purpose AI tool, not a legal-specific one, to insert 48 citations of Supreme Court judgments and a General Council of the Judiciary report that did not exist, as the TSJC's documentalist verified, and did not check the tool's output against the case-law databases.","causal_attribution":"The court's findings in its order as set out in its release; the lawyer admitted the facts (c3)."},{"id":"c3","status":"documented","evidence":[{"locator":"420 euros, la mitad del coste aproximado de una suscripción anual a una herramienta de Inteligencia Artificial específicamente jurídica; admitió los hechos y reconoció su responsabilidad de forma expresa, manifestando un arrepentimiento “aparentemente sincero”","relation":"supports","source_id":"s1"}],"assertion":"The court set the fine at about half the annual subscription cost of a legal-specific AI tool, taking into account that the lawyer admitted the facts, expressly accepted responsibility and expressed apparently sincere remorse.","causal_attribution":"The court's release."},{"id":"c4","status":"reported","evidence":[{"locator":"el letrado citó al menos siete resoluciones del Supremo y un informe que no aparecen en las bases de datos; fio su trabajo, sin mayor revisión, a lo que el algoritmo le propuso; desestima el recurso de la acusación particular contra la absolución; la sala ordena formar pieza separada","relation":"supports","source_id":"s3"}],"assertion":"In a judgment dismissing the appeal, reported on 5 January 2026, the TSJC found that it cited at least seven Supreme Court rulings and a report absent from the databases, said the lawyer appeared to have relied without further review on what the algorithm proposed, and ordered a separate proceeding on the lawyer's responsibility.","causal_attribution":"Expansión's report of the court's press note and its quotations from the judgment."},{"id":"c5","status":"reported","evidence":[{"locator":"regretted that his identity had been revealed when the case became public; he had been the object of “comments and mockery in different professional environments, including group chats of lawyers of which I am a part”; it sees itself obliged to make clear that the Communication Office did not incur in any reprehensible conduct","relation":"supports","source_id":"s2"}],"assertion":"In the sanction proceeding the lawyer complained that the case's publication made the lawyer identifiable and led to comments and mockery in professional circles, including lawyers' group chats; the court said its communication office had not acted improperly.","causal_attribution":"The lawyer's submissions as recorded in the order, reported by La Voz de Lanzarote; the mockery followed the publicity about the AI citations."}],"effects":[{"label":"fined 420 euros and referred to the bar association over false citations generated with an AI tool","claim_id":"c1","direction":"negative"},{"label":"the lawyer told the court of comments and mockery from colleagues after the case became public","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.poderjudicial.es/cgpj/es/Poder-Judicial/Noticias-Judiciales/El-TSJ-de-Canarias-multa-a-un-abogado-por-citar-hasta-48-sentencias-falsas-sugeridas-por-IA","kind":"court_press_release","access":"read","language":"es","translation_note":"Read in Spanish on 2026-10-16 from the Poder Judicial website (HTTP 200); quoted passages were translated by the research agent (an AI). Dated 13 February 2026 in the page metadata.","independence_group":"tsjc-canarias-sanction-order-february-2026"},{"id":"s2","url":"https://www.lavozdelanzarote.com/en/news/courts/lawyer-who-cited-non-existent-sentences-made-by-artificial-intelligence-is-ordered-to-pay-fine_241336_102.html","kind":"news","access":"read","language":"en","translation_note":"Read on 2026-10-16 (HTTP 200) in La Voz de Lanzarote's English edition, a translation of its Spanish report; its account repeats the court's release and adds passages from the order on the lawyer's submissions. Published 13 February 2026.","independence_group":"tsjc-canarias-sanction-order-february-2026"},{"id":"s3","url":"https://www.expansion.com/juridico/actualidad-tendencias/2026/01/05/695bae72e5fdeac6088b4595.html","kind":"news","access":"read","language":"es","translation_note":"Read in Spanish on 2026-10-16 (HTTP 200); quoted passages were translated by the research agent (an AI). Published 5 January 2026; reports the TSJC's press note and quotes its judgment.","independence_group":"tsjc-canarias-appeal-judgment-january-2026"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["The name of the AI tool.","The dates on which the appeal was filed and the sanction order was issued (the order was announced on 13 February 2026). The appeal predates the judgment that Expansión on 5 January 2026 says was notified days earlier, so the false citations were probably filed before 2026; the 2026 date recorded here is the year of the sanction.","Whether the false citations affected the outcome of the appeal; no source says so.","The outcome of the bar association referral."],"geography":{"basis":"The appeal was filed with, and the fine imposed by, the High Court of Justice of the Canary Islands (Spain) against a judgment of the Provincial Court of Santa Cruz de Tenerife. Where the lawyer lives is not recorded from a press headline.","court_countries":["ES"],"event_countries":["ES"],"affected_person_countries":[]},"publication":{"basis":"Published as a concrete adverse consequence of AI use: the TSJC's order, as described in its release, finds that a general-purpose AI tool generated the 48 false citations the lawyer filed, and fines the lawyer 420 euros with a referral to the bar association.","reviewed_on":"2026-10-16"},"ai_involvement":{"basis":"The TSJC's order, as set out in the court's press release, finds that the lawyer used a general-purpose AI tool to insert 48 citations of Supreme Court judgments and a General Council report that did not exist, and that the lawyer did not check the tool's output against the case-law database. The tool's output reached the lawyer and went into the appeal (communicated_with); the court fined the lawyer for it. The lawyer admitted the facts. The tool is not named.","status":"supported"},"person_relations":["communicated_with"]},"name":"Canary Islands high court fines a lawyer 420 euros for an appeal citing 48 non-existent judgments that it says a general-purpose AI tool generated","summary":"The Criminal Chamber of the High Court of Justice of the Canary Islands (TSJC) fined a lawyer 420 euros for breaching the duty of truthfulness and good faith, after an appeal the lawyer filed contained 48 citations of Supreme Court judgments and a report of the General Council of the Judiciary that did not exist. According to the court's order, as described in its press release of 13 February 2026, the lawyer used a general-purpose AI tool to draft the appeal and did not check a single citation against the free public case-law database; the court's documentalist verified that the references were false. The court referred the matter to the lawyer's bar association for possible disciplinary action and set the fine at about half the annual cost of a legal-specific AI tool, taking into account that the lawyer admitted the facts and expressed remorse. The court had first flagged the citations in its judgment dismissing the appeal, reported on 5 January 2026, which opened a separate proceeding. The lawyer told the court of comments and mockery from colleagues after the case became public.","incidentDate":"2026-01-01","incidentKind":"single_event","incidentDatePrecision":"year","exposurePattern":"unknown","reportedDate":"2026-01-05","aiSystem":"A general-purpose generative AI tool (not a legal-specific product, per the court) used to draft a criminal appeal; the tool is not named","aiProduct":"Unidentified AI drafting tool","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["financial_loss","legal_harm","reputational_harm"],"harmOutcomeSummary":"According to the TSJC, a lawyer whose appeal contained 48 false citations generated with a general-purpose AI tool was fined 420 euros and referred to the bar association; the lawyer told the court of mockery in professional circles once the case became public.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the lawyer fined by the TSJC. The client's position is not described as affected by the false citations, so the client is not counted.","victimAgeRange":"adult","jurisdiction":"ES","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.poderjudicial.es/cgpj/es/Poder-Judicial/Noticias-Judiciales/El-TSJ-de-Canarias-multa-a-un-abogado-por-citar-hasta-48-sentencias-falsas-sugeridas-por-IA","primarySourceLabel":"Poder Judicial (CGPJ), El TSJ de Canarias multa a un abogado por citar hasta 48 sentencias falsas sugeridas por IA (13 February 2026)","firstPublishedAt":"2026-10-16T03:07:45.067439+00:00","updatedAt":"2026-10-16T03:07:45.067439+00:00","scopeVersion":"facts-v3","tags":["spain","legal-profession","hallucinated-citations","court-fine","bar-referral"]},{"id":"2026-new-york-federal-court-defaults-client-and-orders-lawyer-to-pay-fees-over-ai-generated-false-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'motion to dismiss that was peppered with false citations'; 'Top alerted the Court to a series of faulty citations'; 'Defendants Top Experience Company LLC (“Top”) and'; 'cited that did not exist, and eight cases that did exist but did not contain the quotes'; 'Once again, his brief contained false citations'","relation":"supports","source_id":"s2"}],"assertion":"In June 2025 the defendant's lawyer filed a brief supporting its motion to dismiss that, a co-defendant's lawyer showed, cited at least thirteen cases that did not exist and eight real cases that did not contain the quoted words; a later response to the court and a proposed reply brief also contained false citations.","causal_attribution":"The court's findings in its sanctions opinion."},{"id":"c2","status":"documented","evidence":[{"locator":"'unreported cases located via Google Scholar, Google search, or the AI-assisted platform vLex, and then cite-checking those cases by running the brief through a different AI program'; 'introduced citation errors that he mistook as corrections and thus neither reviewed nor fixed'; 'I used generative AI to confirm that the information that I wrote was correctly referencing the information that I had'; 'The tool he claimed to use was NotebookLM'; 'The Court does not find the second explanation credible'; 'Court finds that explanation extremely difficult to believe'","relation":"supports","source_id":"s2"}],"assertion":"The lawyer said he located unreported cases through Google Scholar, Google search and the AI-assisted platform vLex, cite-checked the brief by running it through AI programs (vLex or Paxton AI) that he said introduced the errors, and used NotebookLM to review the content of his response; the court did not find his account of how the errors arose credible and found his NotebookLM account extremely difficult to believe.","causal_attribution":"Documented as the lawyer's statements recorded by the court; his account of how the errors arose is his own and the court rejected it in part."},{"id":"c3","status":"documented","evidence":[{"locator":"'by submitting false citations to the Court produced by generative artificial intelligence (“AI”) and then lying about their genesis'; 'had acted in bad faith'","relation":"supports","source_id":"s1"}],"assertion":"The court later described the sanctioned conduct as submitting false citations produced by generative AI and then lying about their origin, and recalled its finding that the lawyer acted in bad faith.","causal_attribution":"The court's own characterisation in the 9 October 2026 order."},{"id":"c4","status":"documented","evidence":[{"locator":"'by striking Affable’s submissions and entering default judgment against it'; 'nor a client from its attorney’s misdeeds'; 'to enter judgment in favor of Plaintiffs and against Affable Avenue LLC'; 'Dated: February 5, 2026'","relation":"supports","source_id":"s2"},{"locator":"'Court imposed terminal sanctions on Affable'","relation":"supports","source_id":"s1"}],"assertion":"On 5 February 2026 the court sanctioned the lawyer by striking his client's motion papers and entering default judgment against the client, holding that a client is not excused from its lawyer's misdeeds.","causal_attribution":"The court's order; the court ties the sanction to the false citations."},{"id":"c5","status":"documented","evidence":[{"locator":"'then-counsel to Defendant Top Experience Company LLC (“Top”), who had provided substantial assistance to the Court by investigating and reporting'; 'awards his firm $38,877.59'; 'for a total award of $38,877.59'; 'must be made by'; 'within 30 days of this Opinion, unless'; 'Dated: October 9, 2026'","relation":"supports","source_id":"s1"}],"assertion":"On 9 October 2026 the court awarded the firm of a co-defendant's former lawyer, who had investigated and reported the false citations, $38,877.59 in fees and costs, payable by the sanctioned lawyer within 30 days.","causal_attribution":"The court's order."}],"effects":[{"label":"client's motion papers struck and default judgment entered against it as a sanction on its lawyer","claim_id":"c4","direction":"negative"},{"label":"lawyer ordered to pay $38,877.59 in fees and costs","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.364.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-16 from CourtListener RECAP storage (HTTP 200, text extracted with pdftotext); no translation was needed. ECF 364, 18 pp.","independence_group":"sdny-24-civ-9429-court-orders"},{"id":"s2","url":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.227.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-16 from CourtListener RECAP storage (HTTP 200, text extracted with pdftotext); no translation was needed. ECF 227, 33 pp.","independence_group":"sdny-24-civ-9429-court-orders"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["Which tool generated each false citation; the lawyer's account names several tools and the court rejected parts of it.","Whether the lawyer has paid the award, appealed, or been referred to a disciplinary body; neither order mentions a referral.","The amount of damages to be assessed against the defaulted client."],"geography":{"basis":"The filings were made in, and the sanctions imposed by, the U.S. District Court for the Southern District of New York. Where the lawyer and the client are based is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published because the court's two orders, read in full, record the lawyer's own account of using AI tools to find and check citations, describe the false citations as produced by generative AI, and impose default judgment on his client and a $38,877.59 fee award on him because of them.","reviewed_on":"2026-10-16"},"ai_involvement":{"basis":"The lawyer told the court he found cases through the AI-assisted platform vLex and cite-checked his brief by running it through AI programs (vLex or Paxton AI), which he said introduced the errors, and that he used NotebookLM to review a later submission (communicated_with). The court's 9 October 2026 order describes the sanctioned filings as false citations produced by generative AI. The court read those citations and, because of them, struck the client's papers, entered default judgment against the client and ordered the lawyer to pay fees (informed_decision_about). Which tool generated each false citation is not established.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"New York federal court enters default judgment against a defendant and orders its lawyer to pay $38,877 after false citations it found AI produced","summary":"In a federal trademark suit in the U.S. District Court for the Southern District of New York, the court on 5 February 2026 struck a company defendant's motion papers and entered default judgment against it as a sanction on its lawyer, after his filings repeatedly cited nonexistent cases and misattributed quotations. The lawyer said he had found and cite-checked cases with AI tools (vLex and Paxton AI) and used NotebookLM to review a later submission; the court rejected his explanations and found he acted in bad faith. On 9 October 2026 the court described the citations as produced by generative AI and ordered the lawyer to pay $38,877.59 in fees and costs to the firm of a co-defendant's former lawyer, who had reported the false citations to the court.","incidentDate":"2026-02-05","incidentEndDate":"2026-10-09","incidentKind":"bounded_series","incidentDatePrecision":"day","exposurePattern":"repeated_interactions","reportedDate":"2026-02-05","aiSystem":"AI legal research and cite-checking tools the lawyer said he used (vLex with AI functionality, Paxton AI) and NotebookLM, which he said he used to review his response to the court; the court found the citations were produced by generative AI","aiProduct":"vLex, Paxton AI and NotebookLM (reported)","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm","financial_loss"],"harmOutcomeSummary":"According to the court's orders, the defendant's motion papers were struck and default judgment entered against it as a sanction for its lawyer's filings with false citations, which the court describes as produced by generative AI, and the lawyer was ordered to pay $38,877.59 in fees and costs.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"partial","affectedCountEvidence":"One person counted: the lawyer, who described his own use of AI tools and was ordered to pay $38,877.59. The client against which default judgment was entered is a company; the people behind it are not described and are not counted.","victimAgeRange":"adult","jurisdiction":"US-NY","platformType":"other","outcomeStatus":"ongoing","primarySourceUrl":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.364.0.pdf","primarySourceLabel":"U.S. District Court for the Southern District of New York, Opinion and Order on fees, ECF 364, 24 Civ. 9429 (9 October 2026)","firstPublishedAt":"2026-10-16T03:05:26.378079+00:00","updatedAt":"2026-10-16T03:05:26.378079+00:00","scopeVersion":"facts-v3","tags":["united-states","new-york","legal-profession","sanction","hallucinated-citations","default-judgment","attorney-fees"]},{"id":"2026-alabama-supreme-court-dismisses-family-trust-appeal-over-lawyer-ai-hallucinated-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'filed briefs in this appeal that contain numerous invalid, inaccurate, and/or irrelevant citations to legal authorities'; 'They appear to be artificial-intelligence (\"AI\") \"hallucinations,\" i.e., fake authorities created by an AI system'; 'Most of the legal authorities in the briefs are misquoted or nonexistent'","relation":"supports","source_id":"s1"}],"assertion":"The appellants' lawyer filed briefs whose citations the court found numerous, invalid, inaccurate or irrelevant, most of them misquoted or nonexistent, and which the court said appear to be AI hallucinations.","causal_attribution":"The court's own findings."},{"id":"c2","status":"documented","evidence":[{"locator":"'first use of an AI research tool that summarized commentary not readily available through standard legal databases'","relation":"supports","source_id":"s1"}],"assertion":"In a reply-brief footnote quoted by the court, the lawyer attributed two misquotations to an AI research tool that summarised commentary.","causal_attribution":"The lawyer's statement as quoted in the opinion."},{"id":"c3","status":"documented","evidence":[{"locator":"'Hall admitted that many of the legal authorities in his briefs do not exist and that he improperly used AI to obtain those authorities'; 'Hall also informed the Court that he had self-reported his actions to the Alabama State Bar'","relation":"supports","source_id":"s1"}],"assertion":"At the 4 February 2026 show-cause hearing the lawyer admitted that many authorities in his briefs did not exist and that he had improperly used AI to obtain them, and said he had self-reported to the Alabama State Bar.","causal_attribution":"The court's record of the hearing."},{"id":"c4","status":"documented","evidence":[{"locator":"'Because those briefs are grossly deficient under the Alabama Rules of Appellate Procedure, we dismiss the appeal'; 'the dismissal of this appeal is imposed as a sanction because of the particularly egregious facts before us'","relation":"supports","source_id":"s1"}],"assertion":"The court dismissed the appeal because the briefs were grossly deficient, and said the dismissal was imposed as a sanction because of the particularly egregious facts.","causal_attribution":"Established by the opinion."},{"id":"c5","status":"documented","evidence":[{"locator":"'Hall is hereby ordered to pay attorney fees and costs'; 'in the amount of $17,200'; 'Hall is ordered to pay double costs'; 'We also refer Hall to the Alabama State Bar for potential discipline'","relation":"supports","source_id":"s1"}],"assertion":"The court ordered the lawyer to pay $17,200 in attorney fees and costs and double costs of the appeal, and referred him to the Alabama State Bar for potential discipline.","causal_attribution":"Established by the opinion."},{"id":"c6","status":"documented","evidence":[{"locator":"'SELLERS, Justice (concurring in part and dissenting in part)'; 'I do not agree that dismissal of the appeal is appropriate as a sanction for the conduct of a lawyer'; 'I would affirm the judgment of the Mobile Circuit'; 'MENDHEIM, Justice (concurring in part and dissenting in part)'; 'I concur in the dismissal of this appeal'; 'His representation on appeal was of no benefit to them'","relation":"supports","source_id":"s1"}],"assertion":"Justice Sellers, concurring in part and dissenting in part, disagreed that dismissal was an appropriate sanction for a lawyer's conduct but would have affirmed the trial court's judgment on the merits; Justice Mendheim, who concurred in the dismissal, wrote that the lawyer's representation on appeal was of no benefit to the clients.","causal_attribution":"Two separate opinions in the same record; neither is the court's holding."}],"effects":[{"label":"two appellants' appeal was dismissed as a sanction because their lawyer's briefs relied on AI-obtained authorities that were fake or misquoted","claim_id":"c4","direction":"negative"},{"label":"the lawyer was ordered to pay $17,200 and double costs, barred from filing alone in the court and referred to the state bar","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://publicportal-api.alappeals.gov/courts/68f021c4-6a44-4735-9a76-5360b2e8af13/cms/case/47683AFC-2F85-469D-8562-9DCA094BB680/docketentrydocuments/D95CDD15-7428-4CC9-8389-3CC27AC88089","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from CourtListener's archived copy of this court PDF (storage.courtlistener.com, HTTP 200, text extracted with pdftotext) because the court portal URL returned HTTP 403 to the agent; no translation was needed.","independence_group":"alabama-supreme-court-sc-2025-0106"}],"version":1,"ai_roles":["own_use","others_use"],"contexts":["justice","work","relationships"],"unknowns":["Which AI tool the lawyer used; the opinion names none.","Whether the dismissal changed the clients' substantive position; the trial court's summary judgment stands, the main opinion does not decide the merits, and one justice would have affirmed the judgment.","The outcome of the Alabama State Bar referral."],"geography":{"basis":"The appeal was decided by the Supreme Court of Alabama on appeal from the Mobile Circuit Court. The appellants' residence is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published because the Supreme Court of Alabama's opinion establishes that it dismissed two appellants' appeal as a sanction after their lawyer filed briefs built on fabricated authorities that he admitted he had obtained by improperly using AI, and that it sanctioned the lawyer and referred him to the state bar. The opinion was read in full.","reviewed_on":"2026-10-14"},"ai_involvement":{"basis":"The court found the briefs' authorities appeared to be AI hallucinations, the lawyer admitted at the show-cause hearing that he had improperly used AI to obtain authorities that do not exist, and his reply-brief footnote quoted by the court says an AI research tool misattributed quotations. The AI output reached the court through the briefs, and the court dismissed the clients' appeal because those briefs rested on fabricated authorities (informed_decision_about for the clients); the lawyer received the fabricated output from the tool (communicated_with) and was sanctioned.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"Alabama Supreme Court dismisses two siblings' family-trust appeal as a sanction after their lawyer admits using AI that produced fake citations","summary":"On 24 April 2026 the Supreme Court of Alabama dismissed an appeal by two siblings in a family dispute over living trusts because their lawyer, W. Perry Hall, had filed briefs in which most of the legal authorities were misquoted or did not exist. The court said they appeared to be AI hallucinations, and at a show-cause hearing in February 2026 Hall admitted that many authorities did not exist and that he had improperly used AI to obtain them. The court ordered Hall to pay the opposing party's fees and costs of $17,200 and double appeal costs, barred him from filing in the court without a co-signing attorney and referred him to the Alabama State Bar. It said the dismissal was imposed as a sanction because of the particularly egregious facts. One justice, concurring in part and dissenting in part, objected to dismissing the appeal as a sanction for the lawyer's conduct but would have affirmed the judgment against the clients on the merits.","incidentDate":"2026-04-24","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2026-04-24","aiSystem":"An AI research tool that, according to the lawyer's reply-brief footnote quoted by the court, summarised legal commentary and misattributed quotations; the lawyer admitted using AI to obtain authorities that do not exist. No product is named in the opinion","aiProduct":"Unidentified AI research tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm","financial_loss"],"harmOutcomeSummary":"According to the Supreme Court of Alabama, the siblings' appeal was dismissed as a sanction because their lawyer's briefs relied on authorities that were misquoted or did not exist, which he admitted he had obtained by improperly using AI; the lawyer was ordered to pay $17,200 in fees and costs plus double appeal costs and was referred to the state bar.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"One AI user: the appellate lawyer, sanctioned and referred to the bar. Two other people: the two appellants whose appeal was dismissed. The appellee, whose fees were reimbursed, is not counted.","victimAgeRange":"adult","jurisdiction":"US-AL","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://publicportal-api.alappeals.gov/courts/68f021c4-6a44-4735-9a76-5360b2e8af13/cms/case/47683AFC-2F85-469D-8562-9DCA094BB680/docketentrydocuments/D95CDD15-7428-4CC9-8389-3CC27AC88089","primarySourceLabel":"Supreme Court of Alabama, opinion in SC-2025-0106 (released 24 April 2026)","firstPublishedAt":"2026-10-14T03:11:52.987847+00:00","updatedAt":"2026-10-14T03:11:52.987847+00:00","scopeVersion":"facts-v3","tags":["united-states","alabama","legal-profession","sanction","hallucinated-citations","appeal-dismissed"]}]}