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SEVERITY: high Levidow, Levidow & Oberman 2023-06-22 VERIFIED REPORT

Lawyer submits ChatGPT-generated brief with fake case citations, fined by federal court

Attorney Steven Schwartz used ChatGPT to research a personal injury case and submitted a brief citing six entirely fabricated court decisions. Judge P. Kevin Castel sanctioned the firm $5,000.

What happened

In Mata v. Avianca, Steven Schwartz relied on ChatGPT to find supporting case law. ChatGPT generated six fabricated cases with plausible names, citations, and reasoning. When Schwartz asked ChatGPT if the cases were real, the model assured him they could be found on Westlaw and LexisNexis. Schwartz submitted them in a federal filing without verification. Opposing counsel could not find the cases. Judge P. Kevin Castel held a sanctions hearing on June 8, 2023 and issued a decision on June 22, 2023 dismissing the case and fining the firm $5,000. The case became the canonical reference for AI hallucination in professional practice and is taught in U.S. legal education.

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