Courts on AI / Fabricated or misquoted citations
Ruiz v. Magellan Financial & Insurance Services
United States District Court for the District of Arizona · Federal district courts · AZ · · No. 2:23-cv-02090-DWL · order
The District of Arizona publicly reprimands Elizabeth Tate after finding she filed three briefs with fake AI-generated quotations and a fourth with an inaccurate AI-generated case summary. The order says she used ChatGPT, violated Rule 11 and ethics duties, and must report the discipline where required.
- Disposition
- The court issued a formal public reprimand to plaintiff's counsel and required her to report the discipline where required.
- Recorded conduct
- Counsel filed three briefs with fake AI-generated quotations and a fourth with an inaccurate AI-generated summary after using ChatGPT. — outcome: sanctions; actor: lawyer
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
The first issue to be addressed is whether Ms. Tate’s conduct violated any procedural or ethical rules. It did. Ms. Tate acknowledges that she filed three different briefs in this action that contained fake AI-generated quotations and filed a fourth brief that contained an inaccurate AI-generated case summary. ... In the course of preparing this Motion, Ms. Tate utilized ChatGPT to prepare the draft brief. ChatGPT cited the Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003) case to support the proposition that evidence of favorable treatment of the plaintiff or others does not preclude discrimination and may be excluded as irrelevant or misleading. ... Ms. Tate also utilized ChatGPT to assist with the Brief on Impeachment. ... While Ms. Tate confirmed the cases stood for the proposition for which she understood them to when she first prompted ChatGPT to include them in the draft brief, Ms. Tate mistakenly did not correct the misquotations from the Antonakeas or Osazuwa cases.
Authorities cited in the passage: Ansell v. Green Acres Contracting Co., 347 F.3d 515 (3d Cir. 2003) · United States v. Antonakeas, 255 F.3d 714 (9th Cir. 2001) · United States v. Osazuwa, 564 F.3d 1169 (9th Cir. 2009) · Fed. R. Civ. P. 11(b)(2)
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