AI Hallucination Case Stemming from Use of a Paralegal’s AI-Based Research
I blogged yesterday about AI hallucinations in court filings by prominent law firms, as well as a nonexistent source cited in an expert’s declaration (the expert works for leading AI company Anthropic, though at this point it’s not yet clear whether the error stemmed from an AI hallucination or from something else). But I thought I’d blog a bit more in the coming days about AI hallucinations in court filings, just to show how pervasive the problem is: I’m seeing court decisions about this every few days. And those decisions are likely just the tip of the iceberg, since many hallucinations won’t be noted in court decisions, and the great majority of court decisions are state trial court decisions that don’t show up on Westlaw.
Here’s the first case that showed up in my daily WestClip query related to the subject, an opinion yesterday by Judge Rachel Kovner (E.D.N.Y.) in Ramirez v. Humala:
Plaintiff Ramirez’s response letter, … signed by [her lawyer,] Ms. Stillman, cites eight cases. Of the eight, the Court was unable to locate four: (1) London v. Polish Slavic Fed. Credit Union, No. 19-CV-6645, 2020 WL 1275619 (E.D.N.Y. Mar. 17, 2020); (2) Rosario v. 2022 E. Tremont Hous. Dev. Fund Corp., No. 21-CV-9010, 2023 WL 1993700 (S.D.N.Y. Feb. 14, 2023); (3) Paniagua v. El Gallo No. 3 Corp., No. 22-CV-7073, 2024 WL 1046856 (S.D.N.Y. Mar. 11, 2024); and (4) Luna v. Gon Way Constr., Inc., No. 20-CV-893, 2022 WL 826856 (S.D.N.Y. Mar. 18, 2022). The Court ordered Ms. Stillman to either provide copies of the four cases or show cause why she should not be sanctioned for citing nonexistent cases pursuant to Federal Rule of Civil Procedure 11(b) and the inherent power of the Court.
Stillman explained that this originated in the work of her paralegal:
Ms. Ruiz[, Ms. Stillman’s paralegal,] explains that she took the initiative to assist with the legal research for the reply and generated the citations at issue “using secondary tools, including public search resources and AI-based research assistants.”). Ms. Ruiz did not check that the citations she had generated corresponded to real cases before pas
Article from Reason.com
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