{"meta":{"exportedAt":"2026-10-23T16:31:42.785Z","formatVersion":2,"selection":{"q":"hallucination","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":8,"coverage":{"cases":8,"countries":3,"languages":1,"unknownLocation":2,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":8,"minors":0,"coreRelations":5,"contextualRelations":4,"mixedRelations":2,"unknownRelations":1,"relationPending":1,"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":"2025-alabama-federal-court-disqualifies-three-butler-snow-lawyers-over-chatgpt-fabricated-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'On May 7, 2025, Defendant Dunn filed a motion for leave to take the'; 'Then, at 4:21 p.m. on May 12, 2025, Defendant'; 'In total, there were five problematic citations across two motions'","relation":"supports","source_id":"s1"},{"locator":"'filed two motions with five'","relation":"supports","source_id":"s3"}],"assertion":"Two motions filed for the defendant, a former Alabama corrections commissioner, on 7 and 12 May 2025 contained five citations that did not exist or did not support the propositions for which they were cited.","causal_attribution":"Established by the court's own review recorded in the sanctions order."},{"id":"c2","status":"documented","evidence":[{"locator":"'possibly through the use of generative artificial intelligence.'; 'The next day, Plaintiff'; 'On May 14, 2025, the court granted in part and denied in part'; 'conducted independent searches for each allegedly fabricated citation, to no avail'","relation":"supports","source_id":"s1"},{"locator":"'the court has conducted independent searches for each allegedly fabricated citation, to no avail'","relation":"supports","source_id":"s2"}],"assertion":"The plaintiff's response of 15 May 2025 objected that defence counsel appeared to have fabricated citations, possibly through generative AI; the court searched for each citation without result and ordered the signatories and the firm to show cause.","causal_attribution":"Procedural history documented by the order; the Guardian quotes the same show-cause order."},{"id":"c3","status":"documented","evidence":[{"locator":"'In short, attorney Matt Reeves used ChatGPT to obtain'; 'case citations returned by ChatGPT through independent review in Westlaw or'","relation":"supports","source_id":"s1"},{"locator":"'failed to verify the case citations returned by ChatGPT through independent review in Westlaw or Pacer before including them'","relation":"supports","source_id":"s2"}],"assertion":"The lawyers' response stated that partner Matthew Reeves used ChatGPT to obtain case citations for two arguments without verifying them, and Reeves declared that he did not verify the citations ChatGPT returned in Westlaw or PACER.","causal_attribution":"The statements are documented by the order; the AI's role in the citations rests on the lawyers' admission, which the court accepted."},{"id":"c4","status":"documented","evidence":[{"locator":"'the court PUBLICLY REPRIMANDS Mr.'; 'them from further participation in this case; and REFERS this matter to the Alabama'; 'the court exercises its discretion not to suspend them from'; 'SANCTION attorneys Daniel J. Chism and Lynette E. Potter, and the law firm'","relation":"supports","source_id":"s1"},{"locator":"'Manasco also publicly reprimanded the lawyers; referred them to the Alabama State Bar'","relation":"supports","source_id":"s3"}],"assertion":"On 23 July 2025 the court publicly reprimanded three lawyers, disqualified them from the case, referred the matter to the Alabama State Bar and other licensing authorities, declined to suspend them, and released two other lawyers and the firm without sanction.","causal_attribution":"Established by the operative passages of the sanctions order; the ABA Journal relays it."},{"id":"c5","status":"documented","evidence":[{"locator":"'reviewed more than 2,400 separate legal'; 'citations across 330 filings.”'; 'revealed no additional “legal citations that were fabricated,”'","relation":"supports","source_id":"s1"},{"locator":"'No other instances of incorrect case references were found.'","relation":"supports","source_id":"s3"}],"assertion":"Butler Snow commissioned an independent review by Morgan Lewis of more than 2,400 citations across 330 filings. A Morgan Lewis partner declared that the review revealed no additional fabricated citations, and the ABA Journal reports that no other incorrect case references were found.","causal_attribution":"The scope of the review and the Morgan Lewis partner's declaration are documented by the order; the ABA Journal relays the finding."},{"id":"c6","status":"reported","evidence":[{"locator":"'and in these two instances I did not comply with policy'; 'I would hope your honor would not punish my colleagues'","relation":"supports","source_id":"s2"}],"assertion":"At the 21 May 2025 hearing, according to The Guardian, Reeves said he was aware of the limitations on AI use and had not complied with the firm's policy in these two instances, and asked the court not to punish his colleagues.","causal_attribution":"Statements at the hearing as reported by The Guardian."},{"id":"c7","status":"documented","evidence":[{"locator":"'knowledge that Matt Reeves utilized generative artificial intelligence to generate'; 'Mr. Cranford is of counsel at Butler Snow'; 'or substantive review of the legal authorities'","relation":"supports","source_id":"s1"}],"assertion":"The of-counsel lawyer who drafted the motions declared that he had no knowledge that Reeves had used generative AI, and the practice group leader declared that he did not conduct a detailed or substantive review of the legal authorities in the second motion.","causal_attribution":"Declarations summarised and quoted in the sanctions order."}],"effects":[{"label":"three lawyers were publicly reprimanded, disqualified and referred to the state bar over ChatGPT-fabricated citations","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://storage.courtlistener.com/recap/gov.uscourts.alnd.179677/gov.uscourts.alnd.179677.204.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-15 from the RECAP copy of the 51-page order (HTTP 200, text extracted with pdftotext). The declarations, the hearing transcript (Doc. 200) and the Morgan Lewis report it cites were not read separately.","independence_group":"johnson-v-dunn-nd-ala-sanctions-order"},{"id":"s2","url":"https://www.theguardian.com/us-news/2025/may/24/alabama-prison-lawyers-chatgpt-butler-snow","kind":"news_report","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-15 (HTTP 200). The Guardian reports the 21 May 2025 show-cause hearing and quotes the court's order and Reeves's declaration.","independence_group":"guardian-butler-snow-may-2025"},{"id":"s3","url":"https://www.abajournal.com/news/article/5-fabricated-cases-lead-federal-judge-to-kick-3-butler-snow-lawyers-off-case","kind":"news_report","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-15 (HTTP 200). The ABA Journal relays the 23 July 2025 order and Butler Snow's 19 May filing.","independence_group":"johnson-v-dunn-nd-ala-sanctions-order"}],"version":1,"ai_roles":["own_use","others_use"],"contexts":["justice","work"],"unknowns":["The outcome of the referral to the Alabama State Bar and other licensing authorities.","Which version of ChatGPT was used and what prompts produced the citations; the order records the partner's description of a search only.","Whether the disqualification delayed the plaintiff's case beyond the 30-day stay the order mentions."],"geography":{"basis":"The motions were filed in, and the sanctions imposed by, the US District Court for the Northern District of Alabama (sanctions order). Where the partner ran the ChatGPT search 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 order of 23 July 2025 documents that three defence lawyers were publicly reprimanded, disqualified and referred to the state bar over five fabricated or unsupported citations that the lawyers confirmed were hallucinations of ChatGPT, which one partner had used without verifying.","reviewed_on":"2026-10-15"},"ai_involvement":{"basis":"The sanctions order records that three defence lawyers confirmed in writing and at a hearing that the citations were hallucinations of ChatGPT, and quotes their joint response that partner Matthew Reeves used ChatGPT to obtain case citations for two arguments without verifying them; Reeves declared that he searched ChatGPT for supporting case law and did not verify the citations it returned. The court found five citations across the two motions that do not exist or do not support the propositions cited, and sanctioned three lawyers for those false statements. The AI output therefore reached the sanctioned filings through the partner's own exchange with ChatGPT (communicated_with). The drafting lawyer declared that he did not know generative AI had been used, and the practice group leader that he did not substantively review the legal authorities.","status":"supported"},"person_relations":["communicated_with"]},"name":"Alabama federal judge reprimands and disqualifies three Butler Snow lawyers and refers them to the state bar over ChatGPT-fabricated citations (2025)","summary":"In an incarcerated man's lawsuit against Alabama prison officials in the US District Court for the Northern District of Alabama, two motions filed in May 2025 for the defence of a former Alabama corrections commissioner contained five citations that did not exist or did not support the propositions cited. Lawyers of the Butler Snow firm, which the state retains to defend its prisons, told the court that a partner had obtained the citations from ChatGPT and had not verified them. On 23 July 2025 Judge Anna M. Manasco publicly reprimanded three of the firm's lawyers, disqualified them from the case and referred the matter to the Alabama State Bar, and ordered them to give the order to clients, opposing counsel and judges in all their pending cases. She declined to suspend them and released the firm and two other lawyers without sanction.","incidentDate":"2025-05-07","incidentEndDate":"2025-07-23","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-05-24","aiSystem":"ChatGPT, which a Butler Snow partner told the court he used to search for supporting case law; the order records the citations as hallucinations of ChatGPT","aiProduct":"ChatGPT","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","legal_harm"],"harmOutcomeSummary":"According to the court's sanctions order of 23 July 2025, three Butler Snow lawyers were publicly reprimanded, disqualified from the case and referred to the Alabama State Bar after two motions contained citations that the lawyers confirmed were hallucinations of ChatGPT, which one of them had used and not verified.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":2,"affectedCountStatus":"exact","affectedCountEvidence":"Three lawyers sanctioned in the 23 July 2025 order: the partner who declared that he used ChatGPT (counted as the AI user) and the drafting lawyer and the practice group leader, whose own use of ChatGPT is not established (counted as other people harmed). The firm and the two lawyers released without sanction are not counted; the plaintiff and the defendant are not counted as harmed by the AI use.","victimAgeRange":"adult","jurisdiction":"US","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://storage.courtlistener.com/recap/gov.uscourts.alnd.179677/gov.uscourts.alnd.179677.204.0.pdf","primarySourceLabel":"US District Court for the Northern District of Alabama, Johnson v. Dunn, No. 2:21-cv-01701, Sanctions Order (Doc. 204), 23 July 2025","firstPublishedAt":"2026-10-15T03:01:17.679643+00:00","updatedAt":"2026-10-15T03:01:17.679643+00:00","scopeVersion":"facts-v3","tags":["alabama","federal-court","prison-litigation","lawyers","fabricated-citations","chatgpt","disqualification","bar-referral"]},{"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"]},{"id":"2025-uk-upper-tribunal-judicial-review-grounds-false-citations-supervising-solicitor-referred-to-sra","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'lodged judicial review proceedings in the Upper Tribunal'; 'What causes me to make that order are the “authorities” cited at [10], [17], [18], and [32] of the grounds.'; 'and no case with the citation [2010] UKUT 35 (IAC) even exists'","relation":"supports","source_id":"s1"}],"assertion":"Judicial review grounds lodged in the Upper Tribunal on 26 June 2025 cited four authorities that the judge could not find or that carried wrong citations, including one citation that does not exist.","causal_attribution":"Judge's order of 20 August 2025 as set out in the judgment."},{"id":"c2","status":"reported","evidence":[{"locator":"'may have relied on false citations which were generated by AI, as'; 'accepted he had done in this case'","relation":"supports","source_id":"s1"}],"assertion":"The tribunal recorded that the supervising solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case.","causal_attribution":"The tribunal's record of the solicitor's acceptance (the judgment does not say when or in what words he accepted it); no tool, prompt or output is identified."},{"id":"c3","status":"reported","evidence":[{"locator":"'he relied on an outdated precedent on our system, practitioner blogs and personal notes'; 'we were concerned by the suggestion in the statements made by'; 'that the citation errors might have been caused by an “old precedent from previous cases”'; 'He stated that there was no mechanism by which staff at his firm could use AI.'; 'He said that he had, and that he had deleted it.'; 'was unable to offer a clear answer to that question'","relation":"supports","source_id":"s1"}],"assertion":"The solicitor's written explanation of 26 September 2025 said the fee-earner relied on an outdated precedent, practitioner blogs and personal notes, and the tribunal recorded that signed statements by both men suggested the errors might have been caused by an old precedent. At the hearing the solicitor said staff at the firm had no mechanism to use AI, and said he had found and deleted the precedent but could not say what it was.","causal_attribution":"The solicitor's and the fee-earner's own accounts as recorded in the judgment; contrary evidence on the AI origin. The solicitor could not identify the precedent ([53])."},{"id":"c4","status":"documented","evidence":[{"locator":"'we consider that the inclusion of false citations in the grounds for judicial review and'; 'necessitates a referral to the SRA'; 'It matters not how such citation errors come about.'","relation":"supports","source_id":"s1"}],"assertion":"The tribunal referred the supervising solicitor to the Solicitors Regulation Authority because the grounds included false citations and he had failed to supervise their drafting, and said it does not matter how such citation errors come about.","causal_attribution":"Decision stated in the judgment promulgated on 17 November 2025."},{"id":"c5","status":"documented","evidence":[{"locator":"'has now been amended so as to require a legal representative to confirm by a statement of truth that any authority cited within the form'","relation":"supports","source_id":"s1"}],"assertion":"The judgment states that the Upper Tribunal judicial review claim form has been amended to require a legal representative to confirm by a statement of truth that any cited authority exists, can be located with the citation given and supports the proposition for which it is cited.","causal_attribution":"Statement in the judgment's headnote and conclusions."},{"id":"c6","status":"documented","evidence":[{"locator":"'He refused permission for reasons which we need not set out.'","relation":"supports","source_id":"s1"}],"assertion":"Permission to apply for judicial review was refused on 20 August 2025 for reasons the judgment does not set out.","causal_attribution":"Judgment; the refusal is not connected to the citations."}],"effects":[{"label":"supervising solicitor referred to the SRA over false citations in judicial review grounds drafted by a junior fee-earner","claim_id":"c4","direction":"negative"}],"sources":[{"id":"s1","url":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","kind":"court_record","access":"read","language":"en","translation_note":"Full judgment text read in English by the research agent (an AI) on Find Case Law (HTTP 200); no translation was involved and no human reviewer read it.","independence_group":"ukut-2026-81-judgment"}],"version":1,"ai_roles":["others_use"],"contexts":["justice","work"],"unknowns":["Which AI tool generated the false citations, and what was asked of it; the judgment records only the solicitor's acceptance.","Whether the junior fee-earner used an AI tool: he did not attend the hearing, and the statements he and the solicitor signed suggested an old precedent as the source of the errors.","What action, if any, the Solicitors Regulation Authority has taken on the referral.","Whether other files the fee-earner worked on contain false citations; the tribunal said it was likely but unestablished."],"geography":{"basis":"Event: the grounds were lodged in the Upper Tribunal (Immigration and Asylum Chamber), the Hamid hearing was held at Field House and the referral is to the Solicitors Regulation Authority (judgment). Court: the Upper Tribunal. The solicitor's residence is not stated.","court_countries":["GB"],"event_countries":["GB"],"affected_person_countries":[]},"publication":{"basis":"Published on the Upper Tribunal's own judgment: false citations in judicial review grounds led the tribunal to refer the supervising solicitor to the SRA, and the tribunal records his acceptance that the junior fee-earner relied on AI-generated citations. The referral is documented; the AI origin is reported and the solicitor's earlier contrary accounts are recorded. The solicitor, the fee-earner and the applicant are private persons and are not named in the public text.","reviewed_on":"2026-10-12"},"ai_involvement":{"basis":"The judgment records that the solicitor accepted that the junior fee-earner had relied on false citations generated by AI in this case ([52]), and the tribunal referred him to the SRA because the grounds included those false citations and he had failed to supervise their drafting ([56]). The false authorities reached the tribunal in the grounds; the judge identified them, ordered the show cause process and the panel acted on them in deciding to refer the solicitor (informed_decision_about). The AI origin rests on that recorded acceptance and on the tribunal's reference to his failure to put checks in place 'to ensure that the use of AI did not mislead the tribunal' ([46]). Against it, his written explanation had named an outdated precedent, practitioner blogs and personal notes, the statements he and the fee-earner signed suggested an old precedent, which he said he had deleted and could not describe ([53]), at the hearing he said staff had no mechanism to use AI, and the tribunal said the source of the errors does not matter to the referral. No tool or output is identified.","status":"reported"},"person_relations":["informed_decision_about"]},"name":"UK Upper Tribunal refers a supervising solicitor to the SRA over false citations in judicial review grounds; tribunal records he accepted they were AI-generated","summary":"Judicial review grounds lodged in the Upper Tribunal (Immigration and Asylum Chamber) on 26 June 2025 by a solicitors' firm cited four authorities that the judge could not find or that carried wrong citations and propositions. The firm's compliance officer, a solicitor whose name was on the claim form, said a junior fee-earner had drafted the grounds under his supervision; his written explanation named an outdated precedent, practitioner blogs and personal notes as the sources. After a Hamid hearing on 5 November 2025, the tribunal recorded that he accepted the fee-earner had relied on false citations generated by AI, and in a judgment promulgated on 17 November 2025 it referred him to the Solicitors Regulation Authority for the false citations and his failure to supervise. The tribunal said it does not matter how such errors come about. It also announced that the Upper Tribunal judicial review claim form now requires a statement of truth that cited authorities exist and support the propositions they are cited for.","incidentDate":"2025-06-26","incidentEndDate":"2025-11-17","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"unknown","reportedDate":"2025-11-17","aiSystem":"Unidentified AI tool that, according to the tribunal's record of the solicitor's acceptance, generated the false citations a junior fee-earner relied on; no tool is named","aiProduct":"Unidentified AI tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm"],"harmOutcomeSummary":"The supervising solicitor was put through a show cause order and a Hamid hearing and referred to the Solicitors Regulation Authority for false citations in grounds drafted by a junior fee-earner and for failing to supervise ([2026] UKUT 81 (IAC), promulgated 17 November 2025). The AI origin of the citations rests on the tribunal's record that he accepted it; his written explanation had named other sources.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"One person: the supervising solicitor referred to the SRA. He is not counted as an AI user, because the judgment records the junior fee-earner's reliance on AI-generated citations. The fee-earner, who had left the firm and did not attend, and the applicant, whose permission refusal the judgment does not connect to the citations, are not counted.","victimAgeRange":"adult","jurisdiction":"GB","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"pending","primarySourceUrl":"https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/81","primarySourceLabel":"Find Case Law, [2026] UKUT 81 (IAC), UK v SSHD (AI hallucinations; supervision; Hamid), promulgated 17 November 2025","firstPublishedAt":"2026-10-12T03:12:31.6959+00:00","updatedAt":"2026-10-12T03:12:31.6959+00:00","scopeVersion":"facts-v3","tags":["ai-hallucination","fabricated-citations","legal","immigration","tribunal","supervision","sra-referral","united-kingdom"]},{"id":"2025-north-carolina-federal-prosecutor-ai-drafted-brief-fabricated-quotations-reprimand","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"This filing misquoted a Fourth Circuit case, falsely attributed quotes to other cases and incorrectly described the court’s decision in several cases that he relied upon to support his argument, Numbers said.","relation":"supports","source_id":"s3"},{"locator":"Numbers' list of problematic conduct includes fabricated quotes, misrepresentations of previous cases","relation":"supports","source_id":"s1"},{"locator":"filed a response with the court including “fabricated quotations and misstatements of case holdings”","relation":"supports","source_id":"s4"}],"assertion":"A response brief filed in December 2025 by Assistant U.S. Attorney Rudy Renfer for the Department of Defense in Fivehouse v. U.S. Department of Defense misquoted a Fourth Circuit case, attributed quotes to cases that did not contain them and misdescribed the holdings of several cases, according to Magistrate Judge Robert T. Numbers II's orders as reported by the News & Observer and Courthouse News.","causal_attribution":"The court attributed the false quotations to the brief Renfer signed; the fabricated authority is the AI-related artifact in this case."},{"id":"c2","status":"reported","evidence":[{"locator":"flagged fabricated quotes and inaccurate descriptions of court cases in a brief Renfer filed earlier that month.","relation":"supports","source_id":"s1"},{"locator":"In a January court filing, Renfer attributed the errors to an \"inadvertent filing of an unfinalized draft.\"","relation":"supports","source_id":"s1"},{"locator":"Fivehouse pointed out the errors in his reply.","relation":"supports","source_id":"s3"}],"assertion":"The self-represented plaintiff, a retired Air Force colonel, identified the fabricated quotes and inaccurate case descriptions in his reply at the end of December 2025, and Renfer then attributed the errors to the inadvertent filing of an unfinalized draft.","causal_attribution":"none asserted"},{"id":"c3","status":"documented","evidence":[{"locator":"the court orders Assistant United States Attorney Rudy E. Renfer to appear and show cause why he should not be sanctioned. The show cause hearing will be held on Tuesday, March 10, 2026","relation":"supports","source_id":"s5"},{"locator":"must appear at a show-cause hearing this week","relation":"supports","source_id":"s4"}],"assertion":"On 2 March 2026 the court ordered Renfer to appear on 10 March 2026 and show cause why he should not be sanctioned under Rule 11(b)(2) and the court's inherent authority, and asked leadership of the U.S. Attorney's Office to attend.","causal_attribution":"none asserted"},{"id":"c4","status":"reported","evidence":[{"locator":"Renfer then admitted to using AI to draft the brief","relation":"supports","source_id":"s1"},{"locator":"he thought he had edited and fact-checked the brief that AI helped draft. In reality, he sent an unfinished draft to his assistant, directing her to file it","relation":"supports","source_id":"s1"},{"locator":"He told the court that he accidentally saved a new file over the original draft of the brief, “panicked,” and used artificial intelligence to catch up.","relation":"supports","source_id":"s3"}],"assertion":"At the 10 March 2026 hearing Renfer said under oath that, after accidentally saving over his draft of the brief, he panicked and used artificial intelligence to draft it, believed he had edited and fact-checked the AI-assisted draft, and in fact sent an unfinished draft to be filed.","causal_attribution":"Renfer connected the fabricated authority to his use of AI; the court later wrote that an attorney who outsources research and writing to generative AI assumes the risk of fictitious authority."},{"id":"c5","status":"reported","evidence":[{"locator":"Renfer lost his job after resigning from the position he had held for 17 years, he said.","relation":"supports","source_id":"s1"},{"locator":"Renfer also told Numbers, who presided over that hearing, that he had submitted his resignation.","relation":"supports","source_id":"s3"},{"locator":"Renfer was reportedly terminated the next day.","relation":"supports","source_id":"s3"},{"locator":"has asked the Department of Justice's Office of Professional Responsibility to investigate","relation":"supports","source_id":"s1"}],"assertion":"Renfer left the U.S. Attorney's Office, where he had worked for 17 years: he told the court on 10 March 2026 that he had submitted his resignation, and Courthouse News reported that he was terminated the next day; the U.S. Attorney referred him to the Department of Justice's Office of Professional Responsibility.","causal_attribution":"The job loss followed the hearing on the AI-drafted brief; the sources do not state the employer's formal grounds."},{"id":"c6","status":"reported","evidence":[{"locator":"On Tuesday, U.S. Magistrate Judge Robert Numbers II signed an order reprimanding Rudy Renfer","relation":"supports","source_id":"s2"},{"locator":"Numbers limited the punishment to a public reprimand.","relation":"supports","source_id":"s2"},{"locator":"Numbers said Renfer “intentionally submitted a brief containing false materials to the court.”","relation":"supports","source_id":"s3"},{"locator":"His loss of employment imposes a financial burden well beyond the types of fines courts typically","relation":"supports","source_id":"s3"}],"assertion":"On 28 April 2026 Magistrate Judge Numbers signed an order publicly reprimanding Renfer, writing that he intentionally submitted a brief containing false materials, that his professional reputation was in tatters, and that his loss of employment was a financial burden beyond the fines courts typically impose, so no fine was imposed.","causal_attribution":"The court tied the reprimand to the submission of fabricated authority produced with generative AI."}],"effects":[{"label":"a federal prosecutor lost his 17-year position and received a public judicial reprimand after filing an AI-drafted brief with fabricated quotations","claim_id":"c6","direction":"negative"},{"label":"a self-represented litigant had to identify fabricated quotations and misdescribed cases in the government's brief against him","claim_id":"c2","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.yahoo.com/news/articles/judge-weighs-next-steps-us-121054156.html","kind":"news_report","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-09 from the saved body; no translation was involved and no human reviewer read the text. The News & Observer report of 11 March 2026 on the 10 March show-cause hearing, read in its Yahoo News syndication; HTTP 200.","independence_group":"news-and-observer"},{"id":"s2","url":"https://www.yahoo.com/news/articles/federal-judge-punishes-ex-us-173015519.html","kind":"news_report","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-09 from the saved body; no translation was involved and no human reviewer read the text. The News & Observer report of 28 April 2026 on the reprimand order, read in its Yahoo News syndication; HTTP 200.","independence_group":"news-and-observer"},{"id":"s3","url":"https://www.courthousenews.com/judge-rebukes-ex-doj-attorney-for-ai-generated-brief/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-09 from the saved body; no translation was involved and no human reviewer read the text. Courthouse News Service report of 28 April 2026; the publisher host returned HTTP 403 to the fetcher, so the body was read from an Internet Archive capture of the same URL.","independence_group":"courthouse-news"},{"id":"s4","url":"https://www.abajournal.com/news/article/doj-leaders-must-explain-why-attorney-used-fabricated-quotes-in-court-filing","kind":"news_report","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-09 from the saved body; no translation was involved and no human reviewer read the text. ABA Journal, 9 March 2026, relaying Bloomberg Law reporting of the 2 March 2026 show-cause order; it does not mention AI; HTTP 200.","independence_group":"bloomberg-law"},{"id":"s5","url":"https://www.courtlistener.com/docket/71231282/fivehouse-v-us-department-of-defense/?page=2","kind":"court_record","access":"read","language":"en","translation_note":"Read in English by the research agent (an AI) on 2026-10-09 from the saved body; no translation was involved and no human reviewer read the text. CourtListener RECAP docket for Fivehouse v. U.S. Department of Defense, No. 2:25-cv-00041 (E.D.N.C.), page 2, entries of February to March 2026; HTTP 200. The 28 April 2026 order itself was not available as a free document.","independence_group":"court-docket"}],"version":1,"ai_roles":["own_use"],"contexts":["work","justice"],"unknowns":["Which AI tool Renfer used, and whether the whole brief or only parts of it were generated; the inspected accounts say only that he used artificial intelligence to draft the brief after losing his own draft.","Whether Renfer resigned or was terminated: he told the court he had resigned, and Courthouse News reported that he was terminated the next day.","The outcome of the Office of Professional Responsibility referral, and whether the court found similar fabricated quotations in other filings he signed (the News & Observer mentions errors in some of his other briefs without detail).","Any consequence for the self-represented plaintiff beyond the work of identifying the errors; the inspected sources describe none."],"geography":{"basis":"The brief was filed in the U.S. District Court for the Eastern District of North Carolina and the hearing took place at the federal courthouse in Raleigh (docket entry of 2 March 2026; News & Observer). Renfer worked in that district's U.S. Attorney's Office. No other country is involved.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":["US"]},"publication":{"basis":"Published as a core case on two independent reporting chains that both quote the court's orders and both report the attorney's statements at the 10 March 2026 hearing: a federal prosecutor said under oath that he used artificial intelligence to draft a brief that the court found contained fabricated quotations and misdescribed holdings, and the court responded with a show-cause order (documented on the docket), after which he lost his position and received a public reprimand on 28 April 2026. The affected person is a named public actor in a public court record. The AI tool is not identified and the resignation-or-termination question is recorded as unknown.","reviewed_on":"2026-10-09"},"ai_involvement":{"basis":"Renfer stated under oath at the 10 March 2026 show-cause hearing that he used artificial intelligence to draft the response brief after overwriting his own draft, and that he had not verified the cases it cited (News & Observer, 11 March; Courthouse News, 28 April). The court's 28 April order, as quoted by Courthouse News, treated the fabricated quotations and misdescribed holdings in that brief as the output of generative AI that Renfer failed to check ('An attorney who outsources core research and writing obligations to generative AI assumes the risk that its output will contain fictitious authority'); the News & Observer quotes the same order's statement that 'the submission of fabricated authority will not be tolerated in this Court'. The fabricated authority in the filed brief led to the show-cause order, the hearing, his departure from the office and the public reprimand. The tool is not identified in any inspected source.","status":"supported"},"person_relations":["communicated_with"]},"name":"Former federal prosecutor in North Carolina publicly reprimanded after admitting that a brief with fabricated quotations was drafted with AI; he lost his post","summary":"In December 2025 an Assistant U.S. Attorney in the Eastern District of North Carolina filed a response brief for the Department of Defense in a self-represented veteran's lawsuit over health-insurance coverage. The plaintiff identified fabricated quotations and misdescribed case holdings in it. The attorney first attributed the errors to an unfinalized draft filed by mistake. On 2 March 2026 Magistrate Judge Robert T. Numbers II ordered him to show cause why he should not be sanctioned. At the 10 March hearing the attorney, Rudy Renfer, said under oath that he had accidentally overwritten his draft, panicked and used artificial intelligence to draft the brief, and had not verified the cases it cited; he said he had resigned after 17 years in the office, and Courthouse News reported he was terminated the next day. On 28 April 2026 the court issued a public reprimand instead of a fine, writing that his reputation was in tatters and that his job loss already exceeded the usual fines.","incidentDate":"2025-12-23","incidentEndDate":"2026-04-28","incidentKind":"single_event","incidentDatePrecision":"day","exposurePattern":"single_interaction","reportedDate":"2026-03-09","aiSystem":"Generative artificial intelligence tool, not identified in the inspected accounts, that the attorney said he used to draft a response brief in federal court","aiProduct":"Unidentified AI drafting tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm","reputational_harm","legal_harm"],"harmOutcomeSummary":"The attorney lost his position in the U.S. Attorney's Office after 17 years, was referred to the Office of Professional Responsibility and received a public judicial reprimand stating that his professional reputation was in tatters, all following the show-cause proceedings over the AI-drafted brief with fabricated quotations (News & Observer; Courthouse News). The self-represented plaintiff had to identify the fabricated authority in the government's filing; no further consequence for him is reported.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"One AI user harmed: the attorney who said he used AI to draft the brief and who lost his job and was reprimanded. The plaintiff's burden of identifying the errors is described, but no consequence to him is reported, so he is not counted as harmed.","victimAgeRange":"unknown","jurisdiction":"US","platformType":"other","outcomeType":"regulatory_action","outcomeStatus":"resolved","primarySourceUrl":"https://www.yahoo.com/news/articles/judge-weighs-next-steps-us-121054156.html","primarySourceLabel":"The News & Observer (via Yahoo News), 11 March 2026: report of the show-cause hearing at which the attorney admitted using AI","firstPublishedAt":"2026-10-09T03:23:08.421295+00:00","updatedAt":"2026-10-09T03:23:08.421295+00:00","scopeVersion":"facts-v3","tags":["legal","fabricated_citations","hallucination","court_sanction","professional_harm","government","united_states","north_carolina"]},{"id":"2024-tasmania-parole-board-ai-hallucinated-case-law-media-condition-quashed","caseFacts":{"claims":[{"id":"c1","status":"corroborated","evidence":[{"locator":"In December 2024, the Parole Board of Tasmania added a condition that she not speak \"directly or indirectly with any media outlet to claim (her) alleged innocence and/or wrongful conviction\".","relation":"supports","source_id":"s1"},{"locator":"This was replaced by a new parole condition in May 2025","relation":"supports","source_id":"s1"},{"locator":"The condition was tweaked in 2025 to prevent her from communicating directly or indirectly - including through third parties and written statements - with media about her alleged innocence","relation":"supports","source_id":"s2"},{"locator":"The Supreme Court declared that conditions imposed by the Parole Board of Tasmania in December 2024 and May 2025 were invalid and unlawful.","relation":"supports","source_id":"s3"}],"assertion":"In December 2024 the Parole Board of Tasmania added a parole condition barring the parolee from communicating with media to claim her innocence or wrongful conviction, and a broader condition replaced it in May 2025.","causal_attribution":"Not a causal claim."},{"id":"c2","status":"reported","evidence":[{"locator":"used artificial intelligence to prepare a rationale justifying the parole condition, citing case law that was \"fictitious\" and likely \"AI hallucinations\".","relation":"supports","source_id":"s1"},{"locator":"relied upon by the board in creating the conditions, included erroneous AI information, the court was told.","relation":"supports","source_id":"s2"},{"locator":"\"As we now know, those cases didn't exist,\" he said.","relation":"supports","source_id":"s2"}],"assertion":"Her counsel told the Supreme Court that the board's secretary used artificial intelligence to prepare a rationale document justifying the condition and that the case law it cited did not exist.","causal_attribution":"Counsel's statement in court is reported by ABC and AAP. These accounts do not independently verify the generation history or identify the tool. The document itself was not inspected."},{"id":"c3","status":"reported","evidence":[{"locator":"the Board’s decision-making was affected by a document containing legal authorities that were likely AI-generated hallucinations and did not in fact exist","relation":"supports","source_id":"s3"},{"locator":"Justice Estcourt also found that when the parole board made the decision to impose this condition, it had relied on a document that cited case law that was \"fictitious\" and likely \"AI hallucinations\".","relation":"supports","source_id":"s4"}],"assertion":"The Human Rights Law Centre says the State conceded the board's decision-making was affected by a document containing nonexistent authorities likely generated by AI. ABC's 19 September report says the court found the board had relied on the document when imposing the condition.","causal_attribution":"The State's concession as reported by the applicant's representative, and the ABC's report of the court's finding. The ABC's 15 September report says the judge heard this; its 19 September report says the judge found it. The AI origin is stated as likely."},{"id":"c4","status":"corroborated","evidence":[{"locator":"Today in the Supreme Court in Hobart, Justice Stephen Estcourt ruled the condition was invalid because it denied her procedural fairness, was legally unreasonable, and created uncertainty.","relation":"supports","source_id":"s1"},{"locator":"Justice Stephen Estcourt found the condition was made without procedural fairness, was legally unreasonable and was filled with uncertainty.","relation":"supports","source_id":"s2"}],"assertion":"ABC and AAP report that on 15 September 2026 Justice Stephen Estcourt of the Supreme Court of Tasmania ruled the condition invalid because it denied procedural fairness, was legally unreasonable and created uncertainty.","causal_attribution":"The reported grounds of invalidity are procedural fairness, unreasonableness and uncertainty; the AI document is not reported as a separate ground."},{"id":"c5","status":"corroborated","evidence":[{"locator":"The parole board decided to withdraw the condition in August and did not contest it being set aside on Tuesday.","relation":"supports","source_id":"s2"},{"locator":"Mr Coleridge said the parole board met and withdrew the condition that same month","relation":"supports","source_id":"s1"}],"assertion":"The board withdrew the condition in August 2026 and did not contest it being set aside.","causal_attribution":"Not a causal claim."},{"id":"c6","status":"reported","evidence":[{"locator":"The court heard that in August","relation":"supports","source_id":"s1"},{"locator":"brought to the court's attention that the case law referred to in the document did not exist.","relation":"supports","source_id":"s1"}],"assertion":"Her lawyers raised in August 2026 that the case law in the document did not exist, and the board withdrew the condition that month.","causal_attribution":"Counsel's sequence of events; the board refused to explain the withdrawal."},{"id":"c7","status":"reported","evidence":[{"locator":"For almost two years, the conditions imposed by the Parole Board of Tasmania prevented Ms Neill-Fraser from speaking publicly about her claimed innocence","relation":"supports","source_id":"s3"},{"locator":"she had been unable to speak publicly after Tasmania's parole board placed a condition on her release in 2024.","relation":"supports","source_id":"s2"},{"locator":"Any breach of parole could result in the remainder of the sentence having to be served","relation":"supports","source_id":"s6"}],"assertion":"The Human Rights Law Centre says the conditions prevented the parolee from speaking publicly about her claimed innocence for almost two years. The Guardian reports that a parole breach could have meant serving the remaining sentence.","causal_attribution":"The restriction is the effect of the condition; the AI document is one input to the decision that imposed it."},{"id":"c8","status":"reported","evidence":[{"locator":"\"The Parole Board's professional standards will be independently investigated following its use of unverified artificial intelligence in a rationale document which formed part of the materials before the board to impose conditions,\"","relation":"supports","source_id":"s4"}],"assertion":"Tasmania's Attorney-General announced an independent investigation of the Parole Board's professional standards following its use of unverified artificial intelligence in the rationale document.","causal_attribution":"The Attorney-General's statement acknowledges the AI use; it does not quantify its effect on the decision."},{"id":"c9","status":"corroborated","evidence":[{"locator":"\"The Department will undertake a review to determine the extent to which Artificial Intelligence (AI) may have been used to inform past Tasmanian Parole Board decisions,\"","relation":"supports","source_id":"s4"},{"locator":"“The department will undertake a review to determine the extent to which artificial intelligence may have been used to inform past Tasmanian Parole Board decisions,” a justice department spokesperson said.","relation":"supports","source_id":"s5"}],"assertion":"Tasmania's Justice Department said it would review the extent to which AI may have been used to inform past Parole Board decisions.","causal_attribution":"Not a causal claim."}],"effects":[{"label":"a restriction on public speech about claimed innocence from December 2024 until withdrawal in August 2026","claim_id":"c7","direction":"negative"},{"label":"adverse parole decision affected by a rationale document citing likely AI-generated, non-existent case law","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.abc.net.au/news/2026-09-15/susan-neill-fraser-media-ban-parole-board-ai-hallucinations/106302950","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from abc.net.au (HTTP 200). Court reporting of the 15 September 2026 hearing; the judgment and orders were not inspected. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"abc-au"},{"id":"s2","url":"https://www.canberratimes.com.au/story/9350990/murderers-gag-order-lifted-after-troubling-ai-error/","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from canberratimes.com.au (HTTP 200); Australian Associated Press copy of the same hearing, reported independently of the ABC. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"aap"},{"id":"s3","url":"https://www.hrlc.org.au/news/susan-neill-fraser-gag-order-unlawful/","kind":"organisation_statement","access":"read","language":"en","translation_note":"Read in English in full from hrlc.org.au (HTTP 200). Release by the organisation that represented the parolee; its account of the State's concessions is a party-side account. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"hrlc"},{"id":"s4","url":"https://www.abc.net.au/news/2026-09-19/parole-board-ai-use-review-after-neill-fraser-case/107172064","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from abc.net.au (HTTP 200). Same outlet as s1, so the same independence group; carries the Attorney-General's and Justice Department's statements. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"abc-au"},{"id":"s5","url":"https://www.theguardian.com/australia-news/2026/sep/19/tasmania-justice-department-review-ai-artificial-intelligence-fake-citation-murderer-parole-decision-ntwnfb","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from theguardian.com (HTTP 200); credited to a staff reporter with Australian Associated Press, so grouped with s2. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"aap"},{"id":"s6","url":"https://www.theguardian.com/australia-news/2026/sep/26/sue-neill-fraser-yacht-murder-ai-court-case-media-ban-tasmania-ntwnfb","kind":"news_report","access":"read","language":"en","translation_note":"Read in English in full from theguardian.com (HTTP 200); Guardian Australia feature by its own reporter. Retained complete body independently reinspected on 2026-10-06 for this proposal. No translation required.","independence_group":"guardian-au"}],"version":1,"ai_roles":["institutional_use"],"contexts":["justice"],"unknowns":["Which AI tool was used and the extent of its contribution to the rationale. Counsel identified the secretary as its preparer, but the document and generation history were not inspected.","Whether the rationale document informed the December 2024 decision, the May 2025 decision or both.","The text of the judgment or orders, which could not be read (AustLII HTTP 403).","The findings of the independent investigation and of the Justice Department's review of past parole decisions."],"geography":{"basis":"The Parole Board of Tasmania imposed the condition and the Supreme Court of Tasmania in Hobart set it aside (ABC, AAP). The parolee's country of residence is not stated as such in the sources read.","court_countries":["AU"],"event_countries":["AU"],"affected_person_countries":[]},"publication":{"basis":"This is a concrete restriction of a person's speech through a human parole-board decision. Court reporting and the representative's account describe likely AI-generated false authorities used as an input to that decision. The relation is informed_decision_about and does not require the AI text to mention the parolee. The AI origin remains qualified, and the document's precise role in each of the two successive conditions is unknown. The court's reported grounds concern procedural fairness, unreasonableness and uncertainty.","reviewed_on":"2026-10-06"},"ai_involvement":{"basis":"The Human Rights Law Centre reports the State's concession that the board's decision-making was affected by a rationale document containing nonexistent authorities likely generated by AI. ABC and AAP court reports describe the document's use in imposing the media condition, and the Attorney-General's statement reported by ABC acknowledges unverified AI in material used by the board. These sources connect the AI-supplied legal material to a human decision restricting the parolee's speech. The relation is informed_decision_about. The sources do not establish that AI made claims about the parolee herself, wrote the whole rationale or made the final parole decision. The judgment and the rationale document have not been inspected.","status":"supported"},"person_relations":["informed_decision_about"]},"name":"Tasmania parole media ban quashed after state conceded reliance on likely AI-hallucinated case law","summary":"In December 2024 the Parole Board of Tasmania added a condition to the parole of Susan Neill-Fraser, released in 2022 after serving 13 years for murder and who maintains her innocence, barring her from communicating with media to claim innocence or wrongful conviction; a broader condition replaced it in May 2025. On 15 September 2026 the Supreme Court of Tasmania declared the conditions invalid. Her counsel told the court that the board's secretary had used artificial intelligence to prepare a rationale document justifying the condition and that it cited case law that did not exist. The Human Rights Law Centre, which represented her, says the State conceded that the board's decision-making was affected by a document containing legal authorities that were likely AI-generated hallucinations, and the ABC reports the court found the board relied on that document. The board had withdrawn the condition in August 2026. Tasmania's Attorney-General announced an independent investigation of the board's professional standards over its use of unverified AI, and the Justice Department announced a review of AI use in past parole decisions.","incidentDate":"2024-12-01","incidentEndDate":"2026-09-15","incidentKind":"bounded_series","incidentDatePrecision":"month","exposurePattern":"unknown","reportedDate":"2026-09-15","aiSystem":"An unidentified artificial-intelligence tool that, according to counsel and the Attorney-General, was used to prepare a Parole Board rationale document citing case law that did not exist","aiProduct":"Unidentified AI writing tool","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","loss_of_autonomy"],"harmOutcomeSummary":"The conditions restricted a parolee's public speech from December 2024 until their withdrawal in August 2026. They were declared invalid in September. The Human Rights Law Centre says the State conceded the board's decision-making had been affected by nonexistent legal authorities likely generated by AI. The judgment was not directly inspected, and the sources do not establish whether that document informed the original condition, the replacement or both.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"exact","affectedCountEvidence":"One parolee is counted for the reported restriction of her speech. The reviewed sources describe no other identified person harmed by AI use in a parole decision; an announced review of past decisions does not establish additional victims.","victimAgeRange":"elderly","jurisdiction":"AU","platformType":"other","outcomeType":"investigation_opened","outcomeStatus":"ongoing","primarySourceUrl":"https://www.abc.net.au/news/2026-09-15/susan-neill-fraser-media-ban-parole-board-ai-hallucinations/106302950","primarySourceLabel":"ABC News, 15 September 2026: AI hallucinations in parole board submission scuttle media ban on Susan Neill-Fraser","firstPublishedAt":"2026-10-06T04:48:51.9027+00:00","updatedAt":"2026-10-06T04:48:51.9027+00:00","scopeVersion":"facts-v3","tags":["parole","hallucinated-case-law","freedom-of-speech","judicial-review","government-ai-use"]},{"id":"2025-holmen-norway-gdpr","metadataReview":{"version":1,"geography":{"basis":"Carried forward from the 2026-09-15 metadata review and now checked against the inspected noyb press page. noyb describes him as the Norwegian user and refers to his home town without naming it; residence in Trondheim rests on the retained row, so affected-person country is NO by reported residence. The noyb page does not state where he queried ChatGPT or where the output was viewed, so the event location remains unknown after review. The complaint was filed with the Norwegian data protection authority (Datatilsynet), a regulator rather than a court, so court_countries is empty as a reviewed result. This is a metadata review and does not verify the underlying account.","evidence":[{"kind":"existing_record","locator":"Trondheim, Norway","location":"victim_description","supports":["affected_person_countries"],"countries":["NO"]},{"kind":"source_body","locator":"'When the Norwegian user Arve Hjalmar Holmen wanted to find out if ChatGPT had any information about him, he was confronted with a made up horror story'","location":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","supports":["affected_person_countries"],"countries":["NO"]}],"court_countries":[],"event_countries":[],"affected_person_countries":["NO"]},"unresolved":["The location where the ChatGPT output was generated or viewed is not stated in the inspected noyb page or the retained row; event_countries remains empty as a reviewed unknown.","No court proceeding: the Datatilsynet complaint is a regulatory complaint, so court_countries is empty as a reviewed result.","The complaint PDF linked from the noyb page and any Norwegian-language coverage were not inspected; only the English press page was reviewed."],"reviewed_on":"2026-09-23","source_reviews":[{"url":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","notes":"Read live on 2026-09-23 (noyb, 20 March 2025; html lang=en; the page offers translations in other languages). Describes the complainant as a Norwegian user, the fabricated output (murder of two of his children, attempted murder of his third son, 21-year sentence), the mix of real details including his home town, and the complaint filed with the Norwegian Datatilsynet. Does not locate the query or the viewing of the output.","access":"read","language":"en"}]},"name":"Holmen v. OpenAI - Norway GDPR Complaint","summary":"ChatGPT falsely accused Norwegian citizen Arve Hjalmar Holmen of murdering two of his sons, attempting to murder his third son, and being sentenced to 21 years prison. Mixed real personal details with horrific fabrications. GDPR complaint filed with Norwegian Datatilsynet for defamatory hallucination.","incidentDate":"2025-03-01","incidentKind":"single_event","incidentDatePrecision":"month","exposurePattern":"single_interaction","reportedDate":"2025-03-15","aiSystem":"ChatGPT","aiProduct":"ChatGPT","aiCompany":"OpenAI","severity":"medium","verificationStatus":"verified","harmCategories":["psychological_manipulation","identity_destabilization","third_party_harm_facilitation"],"harmOutcomes":["psychological_distress","reputational_harm"],"harmOutcomeSummary":"Arve Hjalmar Holmen discovered ChatGPT combining real personal details with false claims that he murdered two sons and attempted to murder a third. He filed a GDPR complaint over the defamatory output.","frameworkFacets":["P3a","P5b","P5c"],"pathwayDirection":"inward","causationStatus":"alleged","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"exact","affectedCountEvidence":"The regulator complaint documents one named participant's distress and reputational harm.","victimAgeRange":"adult","jurisdiction":"NO","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"ongoing","primarySourceUrl":"https://noyb.eu/en/ai-hallucinations-chatgpt-created-fake-child-murderer","primarySourceLabel":"noyb — 'AI hallucinations: ChatGPT created a fake child murderer', the complaint filed with Datatilsynet","firstPublishedAt":"2026-01-13T10:13:04.624733+00:00","updatedAt":"2026-09-30T01:17:05.427919+00:00","scopeVersion":"participant-v2","tags":["norway","gdpr","chatgpt","defamation","hallucination","noyb","false_accusations"]}]}