1:34 am - October 13, 2025

Recent incidents reveal how AI-generated false information in court filings and testimony is undermining legal credibility, leading to fines, dismissals, and calls for stricter verification of AI-assisted work in the legal profession.

Report: The Challenge of AI Hallucinations in Legal Proceedings

Artificial intelligence (AI) tools, particularly those leveraging large language models (LLMs), are increasingly implicated in the legal domain, where the risk of so-called “hallucinations” — the generation of false but plausible information — poses a significant challenge. An article from Clubic highlights several recent incidents illustrating the problematic use of AI in courtrooms, underscoring the growing concern within the legal profession regarding the reliability of AI-generated content [1].

Incidents of AI Hallucinations in Court

The Clubic article outlines high-profile examples where lawyers relying on AI-generated legal information were sanctioned or otherwise reprimanded. For instance, a federal judge recently recommended a monetary penalty of $15,000 against a lawyer who cited fictitious case law invented by an AI system. Another case involved the dismissal of testimony from a disinformation expert whose statement, drafted using GPT-4o, included references to nonexistent academic articles, thus undermining the credibility of the provided evidence [1]. These incidents clearly demonstrate the potential adverse impacts of uncritical AI use in the legal arena.

Causes and Characteristics of AI Hallucinations

The root of this problem lies in how LLMs operate: by predicting the next sequence of text based on patterns in their training data rather than verifying factual accuracy or referencing authoritative sources. The Clubic piece emphasises that such models can fabricate legal citations and arguments that appear authentic but are entirely without factual basis [1]. This limitation persists even in more sophisticated systems that use retrieval-augmented generation (RAG), designed to ground AI outputs in vetted databases, which nonetheless remain vulnerable to producing hallucinations [1].

Wider Verification and Impacts

The concerns raised by Clubic are consistent with other reports indicating a trend of AI hallucinations affecting court documents and legal arguments. Reuters articles note that experts involved in litigation have been accused of using AI to generate fabricated sources, and lawyers in important cases have admitted to AI hallucinated citations, reinforcing the ubiquity and seriousness of this problem [3][4][6]. Furthermore, law firms such as Morgan & Morgan have issued warnings to their employees concerning the possible consequences — including dismissal — of relying on unverified AI-generated content in legal contexts [1].

Challenges for the Legal Profession

The integration of AI tools in legal practice presents a paradox: while these systems offer efficiency gains and support in managing vast bodies of text, their propensity for hallucinations challenges the legal profession’s foundational requirement for accuracy and rigor [1]. The risk that false information may mislead courts or affect judicial outcomes is a matter of serious professional and ethical concern.

Conclusion

The Clubic article and related sources collectively shed light on an emerging issue at the intersection of AI and law: despite the appeal of AI tools for legal research and document drafting, hallucinations remain a critical hurdle. The legal profession must grapple with ensuring the integrity and reliability of AI-assisted work, potentially through enhanced verification protocols and cautious deployment, to do justice both legally and technologically [1][3][4]. Until then, uncritical reliance on AI-generated legal information carries substantial risks for practitioners and the judicial system alike.

More on this

  1. https://www.clubic.com/actualite-565656-claude-trahit-ses-createurs-en-plein-tribunal-avec-des-faits-inventes.html – Please view link – unable to able to access data
  2. https://www.reuters.com/legal/legalindustry/anthropics-lawyers-take-blame-ai-hallucination-music-publishers-lawsuit-2025-05-15/ – In a copyright lawsuit against AI firm Anthropic by music publishers Universal Music Group, Concord, and ABKCO, an attorney from Latham & Watkins admitted responsibility for an erroneous citation in an expert report. The mistake stemmed from a fabricated citation generated by Anthropic’s AI chatbot, Claude, which provided an incorrect article title and authors despite linking to a valid academic source. This AI ‘hallucination’ has raised concerns with U.S. Magistrate Judge Susan van Keulen, who emphasized the serious implications of such errors in legal proceedings. Plaintiffs’ attorney Matt Oppenheim had earlier flagged the issue, suggesting that Anthropic data scientist Olivia Chen used the AI-generated reference to support their case improperly. Anthropic’s legal team clarified that while a legitimate article did support Chen’s claims, the misleading citation originated from their firm’s use of the AI tool. To prevent future mishaps, Latham & Watkins has introduced stricter review procedures. This incident contributes to a broader pattern of courts encountering challenges with AI-generated misrepresentations in legal documents. The ongoing case, Concord Music Group Inc v. Anthropic PBC, highlights growing tensions between copyright holders and tech companies over the use of protected content to train AI systems.
  3. https://www.reuters.com/legal/litigation/anthropic-expert-accused-using-ai-fabricated-source-copyright-case-2025-05-13/ – A federal judge in San Jose, California, has ordered the AI company Anthropic to respond to accusations that it used a fabricated source generated by AI in a copyright lawsuit filed by music publishers, including Universal Music Group, Concord, and ABKCO. The lawsuit centers on the alleged misuse of copyrighted song lyrics to train Anthropic’s AI chatbot, Claude. During a hearing, the plaintiffs’ attorney, Matt Oppenheim, claimed that an Anthropic data scientist cited a nonexistent academic article to support arguments about how frequently Claude reproduces copyrighted lyrics. The article was allegedly generated by Anthropic’s AI and falsely attributed to a respected journal. Judge Susan van Keulen labeled the incident a serious issue and demanded a prompt response from Anthropic, though she denied an immediate deposition of the expert, Olivia Chen. Anthropic acknowledged a citation error but suggested it might relate to a different, legitimate article. The case underscores growing concerns over AI-generated misinformation in legal documents, as other attorneys have recently faced sanctions for similar hallucinations. The case, Concord Music Group Inc v. Anthropic PBC, reflects the broader legal friction between copyright holders and AI developers regarding content utilization.
  4. https://www.reuters.com/technology/artificial-intelligence/ai-hallucinations-court-papers-spell-trouble-lawyers-2025-02-18/ – AI-generated ‘hallucinations’ are creating problems for lawyers, with courts questioning or disciplining lawyers for including fictitious case citations generated by AI programs. This issue came to light when two Morgan & Morgan lawyers used invented case law in a lawsuit against Walmart, risking sanctions. These incidents highlight a new litigation risk as generative AI tools like ChatGPT become more common in legal practices. While these tools can help reduce research and drafting time, they can also produce false information, leading to serious consequences for lawyers who fail to verify their filings. Attorney ethics rules demand that lawyers vet their work, regardless of the tools used. Legal experts emphasize the need for lawyers to understand AI’s limitations and ensure their court submissions are accurate. Examples of this growing problem include significant fines and required educational courses on AI for offending attorneys.
  5. https://apnews.com/article/5c97cba3f3757d9ab3c2e5840127f765 – On March 26, 2025, Jerome Dewald appeared remotely before the New York State Supreme Court Appellate Division in an employment dispute case using an AI-generated avatar to present his arguments. Dewald, who was representing himself, created the digital avatar through a San Francisco tech product, aiming to deliver a polished presentation in place of his real self. The judges, however, were not informed in advance and promptly halted the video once they realized it was a synthetic avatar. Justice Sallie Manzanet-Daniels expressed disappointment over the lack of disclosure. Dewald later apologized, explaining he had no ill intent and believed the avatar would communicate more effectively. This incident reflects growing tension over AI’s role in the legal sphere. Past cases include lawyers cited for using AI tools that fabricated legal precedents. However, courts like Arizona’s Supreme Court have adopted AI avatars to communicate rulings to the public. Experts suggest such occurrences were inevitable as self-representing litigants explore new technologies without formal legal guidance. Dewald’s appeal remains pending.
  6. https://www.reuters.com/legal/legalindustry/lawyers-walmart-lawsuit-admit-ai-hallucinated-case-citations-2025-02-10/ – Lawyers representing plaintiffs in a lawsuit against Walmart over injuries from a defective hoverboard admitted to mistakenly including fabricated case citations generated by artificial intelligence. A federal judge in Wyoming questioned the legitimacy of nine cited cases, prompting plaintiffs’ attorneys Rudwin Ayala, T. Michael Morgan, and Taly Goody to withdraw the compromised filing. The admissions have spurred internal discussions regarding AI use and training within their law firm, Morgan & Morgan. The underlying lawsuit, filed in July 2023, involves allegations that a hoverboard made by Jetson and sold by Walmart exploded, causing burns and emotional distress. Walmart and Jetson have denied these claims, attributing the fire to a smoking shed. This incident highlights ongoing issues and ethical considerations surrounding the use of AI in legal research.
  7. https://time.com/6989928/ai-artificial-intelligence-hallucinations-prevent/ – Researchers have developed a new method to detect AI hallucinations, where AI tools confidently produce false information. This new algorithm, published in Nature, distinguishes between correct and incorrect AI-generated answers with 79% accuracy, outperforming other methods. The technique focuses on identifying ‘confabulations,’ where AI provides inconsistent incorrect answers, using ‘semantic entropy’ to measure the consistency of responses. This development, though promising, is computationally intensive and addresses only part of the hallucination issue. Researchers, led by Sebastian Farquhar from Oxford University, aim to enhance AI reliability for applications needing high accuracy. However, integrating this method into real-world systems remains challenging, and experts caution against overestimating its immediate impact, emphasizing that the fundamental nature of AI models makes complete elimination of hallucinations unlikely.

Noah Fact Check Pro

The draft above was created using the information available at the time the story first
emerged. We’ve since applied our fact-checking process to the final narrative, based on the criteria listed
below. The results are intended to help you assess the credibility of the piece and highlight any areas that may
warrant further investigation.

Freshness check

Score:
8

Notes:
The narrative includes recent incidents and references to current legal cases, which suggests it is not outdated. However, the absence of specific dates for all incidents might affect its score.

Quotes check

Score:
0

Notes:
There are no direct quotes in the narrative to verify.

Source reliability

Score:
6

Notes:
The narrative originates from Clubic and is supported by references to Reuters articles, which are generally reliable. However, Clubic is not as well-known internationally as major news outlets.

Plausability check

Score:
9

Notes:
The claims about AI hallucinations in legal contexts are plausible and supported by recent reports from reputable sources.

Overall assessment

Verdict (FAIL, OPEN, PASS): PASS

Confidence (LOW, MEDIUM, HIGH): HIGH

Summary:
The narrative is generally reliable, with a high level of plausibility and recent references. However, the lack of specific quotes and the lesser-known status of Clubic compared to major international outlets might affect its credibility.

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