Attorney Avoids Sanctions After AI Fakes Legal Case

In a case highlighting the growing pains of integrating artificial intelligence into the legal profession, a federal judge has decided against sanctioning an immigration attorney who used AI that generated a non-existent case citation in a court filing.

AI Generates Fictitious Legal Precedent

The incident involved attorney Sarnata Reynolds of Ceartas Solutions, who was representing a client, identified as Student Doe, in a lawsuit against the Trump administration. The suit alleged that the student's F-1 visa had been unlawfully terminated. In a brief filed on June 22, Reynolds cited a case titled Moms Against Poverty v. Department of State to argue that her client only needed to show a likelihood of jurisdiction to prevent the case from being dismissed.

The problem was that this case does not exist. It was a "hallucination" created by the artificial intelligence tool Reynolds had used to assist with her legal research.

A Judge's Warning in Lieu of Sanctions

On Thursday, Judge Amit P. Mehta of the D.C. District Court vacated his previous order for Reynolds to show cause for her error. He noted in his minute order that he appreciated and credited her “candid and contrite” response to the court.

However, Judge Mehta also issued a stern admonishment, stating that the use of AI is “no substitute” for an attorney's duty of due diligence. As a condition of avoiding sanctions, the judge ordered that should Reynolds commit a similar error in the future, she must inform that court about this incident.

Attorney Expresses Deep Regret

In her response brief to the court, Reynolds admitted her failure to verify the AI-generated case. She stated that she “deeply regrets” the incident and asked the judge to spare her from sanctions.

The underlying case, Doe v. Noem, was jointly dismissed on June 30, resolving the visa issue for her client. This incident, however, serves as a significant cautionary tale for legal professionals navigating the use of new AI technologies in their practice.