{"meta":{"exportedAt":"2026-10-23T17:40:41.158Z","formatVersion":2,"selection":{"q":"hallucination","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"2025","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":4,"coverage":{"cases":4,"countries":2,"languages":1,"unknownLocation":2,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":4,"minors":0,"coreRelations":2,"contextualRelations":1,"mixedRelations":0,"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":"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":"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":"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"]}]}