{"meta":{"exportedAt":"2026-11-14T10:54:53.596Z","formatVersion":2,"selection":{"q":"legal-research","system":"","harm":"","context":"","country":"","role":"","relation":"","evidence":"","year":"2025","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":0,"languages":1,"unknownLocation":2,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":1,"minors":0,"coreRelations":1,"contextualRelations":1,"mixedRelations":0,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2025-johannesburg-high-court-refers-applicant-lawyers-to-legal-practice-council-over-ai-tool-fictitious-citations","caseFacts":{"claims":[{"id":"c1","status":"reported","evidence":[{"locator":"'two cases cited in Northbound Processing'; 'were fictitious'; 'the revised version contained two additional incorrect citations'","relation":"supports","source_id":"s1"},{"locator":"'heads of argument contained fictitious case citations that appeared to have been generated by artificial intelligence'; 'contained two additional incorrect citations'","relation":"supports","source_id":"s2"}],"assertion":"While preparing judgment in Northbound Processing's urgent application against the South African Diamond and Precious Metals Regulator, the acting judge found that two cases cited in the applicant's heads of argument did not exist, and a corrected version supplied by junior counsel contained two further incorrect citations.","causal_attribution":"The judgment as described by ITWeb and by a law-firm alert; both rest on the same judgment, which was not read."},{"id":"c2","status":"reported","evidence":[{"locator":"'acknowledged that the non-existent citations likely originated from an AI tool'; 'he had used a tool called'; 'which claimed to be trained solely on South African legal sources'","relation":"supports","source_id":"s1"},{"locator":"'counsel acknowledged the use of AI, accepted full responsibility'","relation":"supports","source_id":"s2"}],"assertion":"On the court's direct inquiry, junior counsel acknowledged that the non-existent citations likely originated from an AI tool and said a tool called Legal Genius had been used under deadline pressure.","causal_attribution":"Counsel's statement to the court as relayed by ITWeb; the law-firm alert relays the acknowledgment without naming the tool."},{"id":"c3","status":"reported","evidence":[{"locator":"'found no intent to deceive the court'; 'be referred to the Legal Practice Council for investigation'","relation":"supports","source_id":"s1"},{"locator":"'a referral to the Legal Practice Council for investigation'","relation":"supports","source_id":"s2"}],"assertion":"The judge accepted the legal team's apologies and found no intent to deceive the court, but ordered that the conduct of Northbound's legal practitioners be referred to the Legal Practice Council for investigation.","causal_attribution":"The court's order as described by both accounts of the judgment."},{"id":"c4","status":"reported","evidence":[{"locator":"'While Northbound ultimately succeeded in obtaining the relief sought'","relation":"supports","source_id":"s2"}],"assertion":"Northbound nevertheless obtained the relief it sought in the application.","causal_attribution":"The law-firm alert's account of the judgment."}],"effects":[{"label":"the applicant's legal practitioners were referred to the Legal Practice Council for investigation over fictitious citations","claim_id":"c3","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.itweb.co.za/article/lawyers-face-probe-for-using-hallucinating-genai-in-court/Pero3MZ3221qQb6m","kind":"news_report","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 (HTTP 200). ITWeb reports from court documents it saw; the judgment itself was not available to the agent.","independence_group":"northbound-processing-judgment-zagpjhc"},{"id":"s2","url":"https://www.cliffedekkerhofmeyr.com/en/news/publications/2025/Practice/Employment-Law/combined-employment-and-knowledge-management-alert-4-july-Another-episode-of-fabricated-citations-real-repercussions-South-African-courts-show-no-tolerance-for-AI-hallucinated-cases","kind":"other","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-14 from a 2025 Internet Archive capture (the live page returned HTTP 403). A law-firm client alert analysing the same judgment; same origin as ITWeb.","independence_group":"northbound-processing-judgment-zagpjhc"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["The exact date of the judgment and of the referral order.","How many practitioners were referred and the outcome of any Legal Practice Council investigation.","Which citations Legal Genius produced and whether the tool provider responded."],"geography":{"basis":"The heads were filed in, and the referral ordered by, the Gauteng Division of the High Court, Johannesburg (ITWeb, Cliffe Dekker Hofmeyr). Where counsel prepared the heads is not stated, so no event or affected-person country is recorded from the court seat.","court_countries":["ZA"],"event_countries":[],"affected_person_countries":[]},"publication":{"basis":"Published because two accounts of the judgment report that the court referred the applicant's lawyers to the Legal Practice Council after heads of argument cited non-existent cases, and that junior counsel told the court the citations likely came from the AI tool Legal Genius.","reviewed_on":"2026-10-14"},"ai_involvement":{"basis":"ITWeb, which saw the court documents, reports that on the court's direct inquiry junior counsel acknowledged that the non-existent citations in the heads of argument likely originated from an AI tool and said a tool called Legal Genius had been used under deadline pressure; Cliffe Dekker Hofmeyr's analysis of the judgment says counsel acknowledged the use of AI. The tool's output (citations of cases that do not exist) was filed in the heads, and the court referred the practitioners to the Legal Practice Council because fictitious authorities were placed before it. The attribution rests on counsel's acknowledgment as relayed by these two accounts of the judgment; the judgment itself was not read.","status":"reported"},"person_relations":["communicated_with"]},"name":"Johannesburg High Court refers a company's lawyers to the Legal Practice Council over fictitious citations that junior counsel said likely came from an AI tool","summary":"In an urgent application by Northbound Processing against the South African Diamond and Precious Metals Regulator, Acting Judge DJ Smit of the Gauteng High Court, Johannesburg, found while preparing judgment that two cases cited in the applicant's heads of argument did not exist. According to ITWeb, which saw the court documents, junior counsel first said a wrong version had been filed, a corrected version was found to contain two further incorrect citations, and on the court's direct inquiry junior counsel acknowledged that the citations likely originated from an AI tool called Legal Genius, used under deadline pressure. The judge accepted the legal team's apologies and found no intent to deceive, but referred the conduct of the applicant's legal practitioners to the Legal Practice Council for investigation (June 2025). The applicant obtained the relief it sought.","incidentDate":"2025-06-01","incidentKind":"single_event","incidentDatePrecision":"month","exposurePattern":"unknown","reportedDate":"2025-07-02","aiSystem":"Legal Genius, an AI legal research tool that junior counsel told the court had been used and which, junior counsel said, claimed to be trained solely on South African legal sources","aiProduct":"Legal Genius (reported)","severity":"low","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["professional_harm"],"harmOutcomeSummary":"According to ITWeb and a law-firm alert on the judgment, the court referred the applicant's legal practitioners to the Legal Practice Council for investigation after heads of argument cited non-existent cases that junior counsel said likely came from the AI tool Legal Genius.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"partial","affectedCountEvidence":"One person counted: the junior counsel who told the court the tool had been used, among the legal practitioners whose conduct was referred. The order refers the practitioners as a group and the sources read do not state how many were referred, so others are unquantified. The applicant company is not counted.","victimAgeRange":"adult","jurisdiction":"ZA","platformType":"assistant","outcomeType":"regulatory_action","outcomeStatus":"ongoing","primarySourceUrl":"https://www.itweb.co.za/article/lawyers-face-probe-for-using-hallucinating-genai-in-court/Pero3MZ3221qQb6m","primarySourceLabel":"ITWeb, 2 July 2025: Lawyers face probe for using hallucinating GenAI in court","firstPublishedAt":"2026-10-14T03:03:33.803607+00:00","updatedAt":"2026-10-14T03:03:33.803607+00:00","scopeVersion":"facts-v3","tags":["south-africa","johannesburg","high-court","fictitious-citations","legal-practice-council","legal-research-tool"]},{"id":"2025-lacey-insurance-discovery-relief-denied-ai-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"ECF 119 p. 8 para 20: 'I have struck, and decline to'; 'consider, any of the supplemental briefs'; 'I decline to award any of the discovery relief'; p. 7 para 17: 'The initial, undisclosed use of AI products to'; 'generate the first draft of the brief was flat-out wrong.'","relation":"supports","source_id":"s1"}],"assertion":"The special master struck the claimant's supplemental briefs and denied the discovery relief she sought because her lawyers filed briefs built on unverified AI-generated legal research.","causal_attribution":"The order itself connects the struck briefs and denial of relief to counsel's undisclosed AI use, failure to cite-check and re-submission of the defective brief (paras 17-20)."},{"id":"c2","status":"documented","evidence":[{"locator":"ECF 119 p. 2 para 5: 'approximately nine of the 27 legal'; 'citations in the ten-page brief were incorrect in some way. At least two of the'; 'authorities cited do not exist at all.'","relation":"supports","source_id":"s1"}],"assertion":"The order records that about nine of the 27 citations in the ten-page brief were incorrect and that at least two cited authorities do not exist.","causal_attribution":"The special master's own after-the-fact review, as recorded in the order."},{"id":"c3","status":"documented","evidence":[{"locator":"ECF 119 p. 10 para 24: 'clearly not at fault for the AI debacle'; 'She will not, however, be financially'; para 25: 'I decline to order any sanction'; conclusion: 'aggregate amount of $31,100.'","relation":"supports","source_id":"s1"}],"assertion":"The order makes the two firms jointly and severally pay $31,100 in aggregate, states the client was not at fault and will not be financially responsible for the awards, and declines any sanction against individual lawyers.","causal_attribution":"Allocation of financial responsibility is directly recorded in the order."},{"id":"c4","status":"reported","evidence":[{"locator":"ECF 119 appendix, declaration p. 46 para 3: 'generative AI capabilities found in CoCounsel and Westlaw Precision and'; p. 47 para 4: 'It is unclear to me whether'; 'research tools I utilized returned some erroneous information.'","relation":"supports","source_id":"s1"}],"assertion":"One lawyer's sworn declaration says the outline he circulated relied in part on generative AI features in CoCounsel, Westlaw Precision and Google Gemini, and that he cannot tell whether particular errors arose from his transcription or from a tool.","causal_attribution":"The declarant's own statement; the order does not determine which tool produced each error."},{"id":"c5","status":"reported","evidence":[{"locator":"ECF 119 appendix, joint response section II p. 76: 'None of the K&L Gates attorneys who worked on the subject brief used any'; order p. 3 para 7: 'the attorneys at K&L Gates didn’t'","relation":"supports","source_id":"s1"}],"assertion":"The second firm states that none of its lawyers who worked on the brief used or had access to AI tools or knew that AI had been used until the special master's inquiries.","causal_attribution":"The firm's own submission; the order records that the special master had no reason to doubt the sworn statements."}],"effects":[{"label":"Loss of requested discovery relief after the claimant's briefs were struck","claim_id":"c1","direction":"negative"}],"sources":[{"id":"s1","url":"https://www.lawnext.com/wp-content/uploads/2025/05/C.D.-Cal.-24-cv-05205-dckt-000119_000-filed-2025-05-06.pdf","kind":"court_order","access":"read","language":"en","translation_note":"English; read on 2026-10-09 from the retained PDF text of the 77-page filing: order pp. 2-10, appendix inventory p. 11, originating lawyer's declaration pp. 46-47 and the firms' joint response section II p. 76. PDF page 1 yielded no text. Not every appended exhibit was read.","independence_group":"lacey-ecf119"}],"version":1,"ai_roles":["others_use"],"contexts":["justice"],"unknowns":["Which tool, if any, produced each erroneous citation or quotation; the declarant says he cannot distinguish his transcription errors from tool output.","Whether the requested discovery relief would have been granted had the briefs been accurate.","The later course of the insurance action and where the AI-assisted drafting took place.","Paragraph 1 of the order (PDF page 1) was not inspected because the page yielded no extractable text."],"geography":{"basis":"The order was issued by a special master in the US District Court for the Central District of California. The record does not state where the AI-assisted drafting took place or where the claimant lives, so event and affected-person countries are left unknown.","court_countries":["US"],"event_countries":[],"affected_person_countries":[]},"publication":{"basis":"A filed court order directly establishes that the claimant's briefs were struck and her discovery relief denied because of AI-generated false citations in her lawyers' filings, with the monetary award placed on the firms. The tool identities are attributed to the declarant and kept as reported.","reviewed_on":"2026-10-09"},"ai_involvement":{"basis":"The filed order records that a lawyer used AI tools to generate the research outline for the claimant's brief and that the resulting brief contained false citations and quotations (about nine of 27 wrong, at least two non-existent). The special master read those authorities, found they did not exist, and on that basis struck the briefs and denied the discovery relief, writing that the use of AI affirmatively misled him. The declarant names CoCounsel, Westlaw Precision and Google Gemini but cannot say which tool produced each error, so the per-tool contribution is unestablished.","status":"supported"},"person_relations":["informed_decision_about"]},"name":"Insurance claimant loses discovery relief after her lawyers file AI-generated false citations; special master's order sanctions the two firms $31,100","summary":"In an order dated 5 May 2025 and filed on 6 May in Lacey v. State Farm (C.D. Cal.), a special master struck the claimant's supplemental briefs and denied the discovery relief she sought after her lawyers filed briefs built on unverified AI-generated legal research: about nine of 27 citations were wrong and at least two cited authorities did not exist. One lawyer's sworn declaration says the outline he circulated relied on generative AI features in CoCounsel, Westlaw Precision and Google Gemini, and that he could not tell whether particular errors came from his transcription or from a tool; co-counsel at the second firm say they used no AI tools and did not know AI had been used. The order makes the two firms jointly pay $31,100, states the client was not at fault and will not bear the awards, and imposes no penalty on individual lawyers.","incidentDate":"2025-04-01","incidentEndDate":"2025-05-05","incidentKind":"bounded_series","incidentDatePrecision":"month","exposurePattern":"unknown","reportedDate":"2025-05-06","aiSystem":"CoCounsel, Westlaw Precision and Google Gemini, named in one lawyer's sworn declaration as the generative AI tools used for the research outline; the order itself refers to 'various AI tools' and does not establish which tool produced each error","aiProduct":"CoCounsel, Westlaw Precision and Gemini (reported)","severity":"medium","verificationStatus":"verified","harmCategories":[],"harmOutcomes":["legal_harm"],"harmOutcomeSummary":"The special master struck the claimant's supplemental briefs and denied the discovery relief she sought after her lawyers filed briefs built on unverified AI-generated citations; the $31,100 award falls on the firms, not on her.","frameworkFacets":[],"causationStatus":"supported","participantUsersAffectedMin":0,"otherPeopleHarmedMin":1,"affectedCountStatus":"documented_minimum","affectedCountEvidence":"One claimant whose briefs were struck and whose discovery relief was denied (order paras 20 and 24). She did not use the AI tools herself, so participant users is 0. The lawyers and firms bear the monetary award but are not counted as harmed persons.","victimAgeRange":"unknown","jurisdiction":"US","platformType":"assistant","primarySourceUrl":"https://www.lawnext.com/wp-content/uploads/2025/05/C.D.-Cal.-24-cv-05205-dckt-000119_000-filed-2025-05-06.pdf","primarySourceLabel":"Lacey v. State Farm General Insurance Co., C.D. Cal. 2:24-cv-05205, ECF 119: special master's sanctions order dated 5 May 2025, filed 6 May 2025 (with appendix)","firstPublishedAt":"2026-09-29T10:29:01.113121+00:00","updatedAt":"2026-10-09T03:12:38.363121+00:00","scopeVersion":"facts-v3","tags":["historical-2025","ai-citations","court-sanction","legal-research","consequential-response"]}]}