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Lawyer sanctioned for fake citations
webCredibility Rating
4/5
High(4)High quality. Established institution or organization with editorial oversight and accountability.
Rating inherited from publication venue: The New York Times
A widely cited real-world case illustrating the dangers of AI hallucinations in high-stakes professional contexts; relevant to discussions of AI deployment safeguards, liability, and the gap between AI capability and reliability.
Metadata
Importance: 62/100news articlenews
Summary
A New York lawyer was sanctioned by a federal judge after submitting a legal brief containing fabricated case citations generated by ChatGPT. The attorney failed to verify the AI-generated citations, which included entirely fictional court decisions. The case became a landmark example of the real-world consequences of AI hallucinations in professional settings.
Key Points
- •Attorney Steven Schwartz used ChatGPT to research cases and submitted citations to nonexistent court decisions in a federal filing.
- •The judge sanctioned the lawyers involved for failing to verify AI-generated legal research before submitting it to the court.
- •ChatGPT confidently fabricated case names, docket numbers, and quotes, illustrating the hallucination problem in large language models.
- •The incident prompted widespread discussion about professional responsibility standards when using AI tools in legal practice.
- •Courts and bar associations began issuing guidance on disclosure and verification requirements for AI-assisted legal work.
Cited by 1 page
| Page | Type | Quality |
|---|---|---|
| AI-Driven Legal Evidence Crisis | Risk | 43.0 |
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Lawyer Who Used ChatGPT Faces Penalty for Made Up Citations - The New York Times
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The Wayback Machine - http://web.archive.org/web/20251107163628/https://www.nytimes.com/2023/06/08/nyregion/lawyer-chatgpt-sanctions.html
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The ChatGPT Lawyer Explains Himself
In a cringe-inducing court hearing, a lawyer who relied on A.I. to craft a motion full of made-up case law said he “did not comprehend” that the chat bot could lead him astray.
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Steven A. Schwartz told a judge considering sanctions that the episode had been “deeply embarrassing.”Credit...Jefferson Siegel for The New York Times
By Benjamin Weiser and Nate Schweber
June 8, 2023
As the court hearing in Manhattan began, the lawyer, Steven A. Schwartz, appeared nervously upbeat, grinning while talking with his legal team. Nearly two hours later, Mr. Schwartz sat slumped, his shoulders drooping and his head rising barely above the back of his chair.
For nearly two hours Thursday, Mr. Schwartz was grilled by a judge in a hearing ordered after the disclosure that the lawyer had created a legal brief for a case in Federal District Court that was filled with fake judicial opinions and legal citations, all generated by ChatGPT. The judge, P. Kevin Castel, said he would now consider whether to impose sanctions on Mr. Schwartz and his partner, Peter LoDuca, whose name was on the brief.
At times during the hearing, Mr. Schwartz squeezed his eyes shut and rubbed his forehead with his left hand. He stammered and his voice dropped. He repeatedly tried to explain why he did not conduct further research into the cases that ChatGPT had provided to him.
“God, I wish I did that, and I didn’t do it,” Mr. Schwartz said, adding that he felt embarrassed, humiliated and deeply remorseful.
“I did not comprehend that ChatGPT could fabricate cases,” he told Judge Castel.
In contrast to Mr. Schwartz’s contrite postures, Judge Castel gesticulated often in exasperation, his voice rising as he asked pointed questions. Repeatedly, the judge lifted both arms in the air, palms up, while asking Mr. Schwartz why he did not better check his work.
As Mr. Schwartz answered the judge’s questions, the reaction in the courtroom, crammed with close to 70 people who included lawyers, law students, law clerks and professors, rippled across the benches. There were gasps, giggles and s
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