Incident Tracker / United States (federal)
Hack v. Preston
·United States District Court for the District of Utah·US-FEDWarningprovisional
The District of Utah addresses Jayne Stephens’s declaration that ChatGPT assisted her filings. The order notes a mischaracterized assertion based on an improperly cited Tenth Circuit case, requires future assistance disclosures, and cautions that GenAI-related Rule 11 violations may be sanctioned.
- Court
- United States District Court for the District of Utah
- Date
- 2026-08-07
- Who used the AI
- Litigant in person
- AI tool
- ChatGPT
- Conduct
- Self-represented defendant used ChatGPT and filed a reply with an improperly cited and mischaracterized Tenth Circuit case.
- Outcome
- Warning
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-07
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Similar incidents on the record
- Johnson v. Dunn, No. 2:21-cv-01701-AMM (N.D. Ala.), 792 F. Supp. 3d 12412025-07-23 · US District Court, Northern District of Alabama (Southern Division) · SanctionsIn the Northern District of Alabama, Judge Anna M. Manasco publicly reprimanded Butler Snow attorneys Matthew B. Reeves, William J. Cranford and William R. Lunsford for filing two motions containing citations hallucinat…
- Mata v Avianca, Inc.2023-06-22 · US District Court, Southern District of New York · SanctionsThe origin case of legal AI hallucination sanctions: two New York attorneys were fined $5,000 after citing six ChatGPT-invented cases in a personal-injury filing and persisting after the fabrications were questioned, pr…
- Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)2026-08-27 · US District Court, Southern District of New York · WarningIn the Southern District of New York, self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District decisions while litigating discovery issues against Amazon. Magistrate Judge Reznik identified the…
- Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)2026-08-26 · US District Court, District of Maryland · WarningIn the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from gen…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Hack v. Preston”, safelegalai.com/tracker/hack-v-preston (accessed 2026-09-08). Data: CC BY 4.0.