AI Hallucinations in a Self-Represented Litigant’s Brief in the Colorado Court of Apeals
Even lawyers have at times filed briefs containing AI-hallucinated citations; but the danger is likely especially great for the many self-represented litigants. Here, for instance, is a passage from the Dec. 26 decision of the Colorado Court of Appeals in Al-Hamim v. Star Hearthstone, LLC, written by Colorado Court of Appeals Judges Lino Lipinsky, joined by Judges Jerry Jones and Grant Sullivan; the underlying case was a landlord-tenant dispute, but I’m focusing here on the discussion of the AI hallucinations:
Al-Hamim’s opening brief in this appeal contained hallucinations, as well as bona fide legal citations. This case provides the first opportunity for a Colorado appellate court to address the appropriate sanction when a self-represented litigant files a brief peppered with GAI-produced hallucinations…. We affirm the court’s judgment against Al-Hamim and put him, the bar, and self-represented litigants on notice that we may impose sanctions if a future filing in this court cites “non-existent judicial opinions with fake quotes and citations.” …
Al-Hamim’s opening brief contains citations to [eight] fake cases …. After we attempted, without success, to locate these cases, we ordered Al-Hamim to provide complete and unedited copies of the cases, or if the citations were GAI hallucinations, to show cause why he should not be sanctioned for citing fake cases. In his response to our show cause order, Al-Hamim admitted that he relied on AI “to assist his preparation” of his opening brief, confirmed that the citations w
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