AI-related case
Morgan v. Community Against Violence
AI UsePlaintiff, acting without counsel, submitted briefing that included multiple fabricated or erroneous judicial citations, likely generated by an AI tool used for research or drafting. While the tool itself is not named, the nature and clustering of errors mirror known AI output patterns.Hallucination DetailsCited cases included wholly nonexistent opinions (e.g., "Las Cruces Sun-News v. City of Las Cruces") and real case names with incorrect volume/reporting details (e.g., misattributed circuits or invented page numbers). The citations lacked verifiable authority and were flagged by the court as spurious upon review.Ruling/SanctionThe court dismissed several claims on substantive grounds but issued a sharp warning about the misuse of AI-generated legal citations. While no immediate sanctions were imposed, the judge explicitly referenced Mata v. Avianca and held this instance to be only the second federal case addressing AI hallucinations in pleadings. The plaintiff was cautioned that any recurrence would result in Rule 11 sanctions, including dismissal with prejudice.Key Judicial ReasoningThe opinion stressed that access to courts is not a license to submit fictitious legal ma…
Judges: William Paul Johnson