The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.
Published opinion, 15 May 2025 · source · PDF · 6 pages
He stated he had "retained a per diem attorney — someone I had previously worked with and trusted — to handle the drafting" of the motion to dismiss and "failed to verify every single citation meticulously, specifically missing the fabricated citation of the 'Greenspan' case[.]" He stated, "[a]lthough I did not personally use AI [(artificial intelligence)] in this case, I failed to ensure that every citation was accurate before filing the brief." [T]he signing attorney cannot leave it to some trusted subordinate, or to one of his partners, to satisfy himself that the filed paper is factually and legally responsible; by signing he represents not merely the fact that it is so, but also the […]
120, 125 (1989)). The court finds that DiPasquale's citation of Greenspan — a nonexistent case — without first attempting to read it to confirm his contention of its holding was not reasonable under the circumstances, and a violation of HRCP Rule 11(b)(2). Cf.
Apr. 24, 2025) (order imposing sanctions) (stating that "an attorney who submits fake cases clearly has not read those nonexistent cases, which is a violation of Rule 11 of the Federal Rules of Civil Procedure"). "[T]he central purpose of [federal] Rule 11 is to deter baseless filings in district court and thus . . . streamline the administration and procedure of the federal courts." Cooter & Gell v.
384, 393 (1990). Federal courts seem to encounter AI-generated citations to nonexistent cases with increasing frequency, "raising the importance of educating and deterring the larger bar from repeating similar conduct." United States v. Hayes , --- F.
Supp. 3d at ---, 2025 WL 1195925, at *9 ($1,000 for citing nonexistent cases "because of [counsel]'s candor and sincere regret"); Dehghani v. Castro , No.
Apr. 2, 2025) (mem. op. & ord.) ($1,500 for citing nonexistent cases); Hayes , --- F. Supp.
Supp. 3d at ---, 2025 WL 235531, at *15 ($1,500 for citing nonexistent case); Gauthier v. Goodyear Tire & Rubber Co., No.
Nov. 25, 2024) (mem. & ord) ($2,000 for citing nonexistent cases and quotations); Wadsworth , 348 F.R.D. at 498 ($3,000 for citing "hallucinated cases"); Mata, 678 F.Supp.3d at 466 ($5,000 for using AI to generate excerpt of nonexistent opinion); Mid Cent. Operating Eng'rs Health & Welfare Fund v.
Published opinion, 12 May 2025 · source · PDF · 6 pages
He stated he had "retained a per diem attorney — someone I had previously worked with and trusted — to handle the drafting" of the motion to dismiss and "failed to verify every single citation meticulously, specifically missing the fabricated citation of the 'Greenspan' case[.]" He stated, "[a]lthough I did not personally use AI [(artificial intelligence)] in this case, I failed to ensure that every citation was accurate before filing the brief." [T]he signing attorney cannot leave it to some trusted subordinate, or to one of his partners, to satisfy himself that the filed paper is factually and legally responsible; by signing he represents not merely the fact that it is so, but also the […]
120, 125 (1989)). The court finds that DiPasquale's citation of Greenspan — a nonexistent case — without first attempting to read it to confirm his contention of its holding was not reasonable under the circumstances, and a violation of HRCP Rule 11(b)(2). Cf.
Apr. 24, 2025) (order imposing sanctions) (stating that "an attorney who submits fake cases clearly has not read those nonexistent cases, which is a violation of Rule 11 of the Federal Rules of Civil Procedure"). "[T]he central purpose of [federal] Rule 11 is to deter baseless filings in district court and thus . . . streamline the administration and procedure of the federal courts." Cooter & Gell v.
384, 393 (1990). Federal courts seem to encounter AI-generated citations to nonexistent cases with increasing frequency, "raising the importance of educating and deterring the larger bar from repeating similar conduct." United States v. Hayes, --- F.
Supp. 3d at ---, 2025 WL 1195925, at *9 ($1,000 for citing nonexistent cases "because of [counsel]'s candor and sincere regret"); Dehghani v. Castro, No.
Apr. 2, 2025) (mem. op. & ord.) ($1,500 for citing nonexistent cases); Hayes, --- F. Supp.
Supp. 3d at ---, 2025 WL 235531, at *15 ($1,500 for citing nonexistent case); Gauthier v. Goodyear Tire & Rubber Co., No.
Nov. 25, 2024) (mem. & ord) ($2,000 for citing nonexistent cases and quotations); Wadsworth, 348 F.R.D. at 498 ($3,000 for citing "hallucinated cases"); Mata, 678 F.Supp.3d at 466 ($5,000 for using AI to generate excerpt of nonexistent opinion); Mid Cent. Operating Eng'rs Health & Welfare Fund v.