{"meta":{"exportedAt":"2026-10-17T09:14:40.829Z","formatVersion":2,"selection":{"q":"litigation","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"","response":"regulatory","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":2,"coverage":{"cases":2,"countries":1,"languages":1,"unknownLocation":1,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":2,"minors":0,"coreRelations":2,"contextualRelations":0,"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":"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"]}]}