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Lawyers Continue to Get in Hot Water For Citing AI Hallucinated Cases

By Linn Foster Freedman on June 20, 2025
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We have previously outlined several cases where lawyers have been sanctioned by courts for citing fake cases generated by artificial intelligence (AI), also known as “hallucinations.”

Now, we don’t even have to keep track of the cases to report on them because we found a nifty new database that keeps track of all of them. Did you know that as of this writing, there have been 156 cases where lawyers cited fake cases generated by AI in court documents?

It is hard to believe that with Rule 11 obligations, any lawyer would file a document with a court without checking the cite. Apparently, it happens more frequently than one would think. Many lawyers have already been sanctioned by courts to send the message that citing fake cases generated by AI is a waste of the court’s time, as well as a waste of the time and resources of opposing counsel and parties.

Kudos to Damien Charlotin, who has created a database to track the growing number of cases where lawyers have cited AI generated hallucinated cases. If you want to see how it is a growing problem, check it out.

The cases grow, and the sanctions continue to get larger and more punitive. Lawyers need to quickly learn that they must follow their ethical obligations and provide actual cases, with citations checked and shepardized with human oversight, before filing a pleading. It is truly shocking that lawyers have failed to do so in 156 instances thus far.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chair’s the firm’s Data Privacy and Security Team. Linn focuses her practice on…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chair’s the firm’s Data Privacy and Security Team. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.

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  • Posted in:
    Intellectual Property
  • Blog:
    Data Privacy + Cybersecurity Insider
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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