Courts on AI / Fabricated or misquoted citations
Amtrust North America o/b/o Justin McGinness v. Liberty Mutual Insurance Company
Superior Court of New Jersey, Appellate Division · State appellate courts · NJ · · 2026 N.J. Super. Unpub. LEXIS 633; 2026 LX 125689 · No. A-2587-24 · opinion
On 2026-03-27, Superior Court of New Jersey, Appellate Division affirmed in part, remanded for dismissal without prejudice, and imposed a $1,000 personal sanction on appellate counsel. Counsel submitted an appellate brief with The appellate brief cited four fabricated insurance cases that resembled real reporter citations but did not exist.
- Disposition
- The court affirmed in part, remanded for dismissal without prejudice, and imposed a $1,000 sanction on plaintiff's attorney payable to the State Treasurer.
- Recorded conduct
- Plaintiff's merits brief cited four cases that do not exist, and counsel failed to retract them after defendants identified the problem. — outcome: fine; actor: lawyer; $1,000
- 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.
look like real cases as they are identified by a case name, a citation dismissal. Indeed, we do not know whether the proper to a reporter, the name of a district or appellate [*9] insurance company would have denied the claim as it court, and the year of the decision. But they are not real has never been tendered to it. cases. However, our review of this matter does not end there. Citation of hallucinated caselaw violates the RPCs, as As stated, plaintiff's counsel cites to four cases in his noted in the Supreme Court's Preliminary AI Guidelines: merits brief that do not exist: RPC 3.3 requires a lawyer to uphold candor to the • "Aetna Cas. & Sur. Co. v. Hanna, 224 N.J. Super. 462 tribunal, including by not knowingly making "a false (App. Div. 1988)." Plaintiff cites this case with the following parenthetical: ("the Appellate Division affirmed 9 A- 2587-24 a workers' compensation carrier's right to subrogation statement of material fact or law . . . ." or offering against an employee's personal UIM benefits.") This "evidence that the lawyer knows to be false . . . ."
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