AI-Hallucinated Citation Case Involving Prominent Alabama Firm (with Over 350 Lawyers Nationwide)
From a filing Monday in Johnson v. Dunn (N.D. Ala.), responding to an order from Judge Anna Manasco demanding an explanation for what she described as apparently “fabricated citations”:
What happened here is unacceptable. Tempted by the convenience of artificial intelligence, counsel improperly used generative AI to supplement two motions and did not verify the citations that AI provided. Those citations turned out to be “hallucinations” by the AI system. Although done without intent to mislead the Court or counsel opposite, counsel do not defend or condone this complete lapse in judgment. They apologize—both for failing to uphold their own standards and for wasting counsel opposite’s and this Court’s time and resources.
Butler Snow [the law firm involved -EV] joins in counsels’ apology to the Court, parties and all counsel, and respectfully requests if the Court decides in its discretion to impose sanctions, that any sanctions be proportionate to the wrong and commensurate with each attorney’s role in these events. Butler Snow also requests that its client not be sanctioned, and for counsel to have the opportunity to file an amended motion with correct citations….
There are no excuses for counsel’s behavior, only explanations. As set forth in the separately filed declarations …, here is what happened: …
In revising Paragraph 2 of the Motion for Leave, Mr. Reeves [a partner in the firm and assistant practice group leader for the firm’s Constitutio
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