Across nearly 300 cases in the United States and abroad, lawyers and self-represented litigants have submitted briefs and legal memoranda containing “hallucinated” decisions and quotations—fabricated citations generated by large-language artificial intelligence programs such as ChatGPT. Courts have sanctioned both attorneys and clients for relying on these false authorities. Hurwitz Fine Insurance Coverage senior member Dan D. Kohane has closely tracked and summarized many of these cases on LinkedIn and was recently asked by the ABA Journal to comment on two of the latest decisions.
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