Incident Tracker

Leiske v. Kidd, C.A. No. 2025-0426-CDW (LWW) (Del. Ch.)

other

In the Delaware Court of Chancery, plaintiffs' counsel filed an answering brief with fictitious citations, fabricated quotations and hallucinated propositions from a generative-AI tool, then only stripped quotation marks when 'correcting' it. Vice Chancellor Lori W. Will issued a Rule 11(c) rule to show cause against signatory Richard P. Rollo and his firm Richards, Layton & Finger; sanctions are pending.

Date of decision/order

2026-07-01

Court

Court of Chancery of Delaware

Jurisdiction

US-STATE

AI tool

Not identified in the record

Conduct

In an advancement dispute, plaintiffs' counsel's answering brief (filed 22 Jan 2026) contained fictitious citations, fabricated quotations and hallucinated legal propositions produced by an unspecified generative-AI ('GenAI') tool used to revise the brief. Counsel admitted failing to verify the citations, attributing the oversight to a paralegal's review; the 'corrected' brief merely removed quotation marks without fixing the false descriptions, and counsel faulted opposing counsel for raising the errors without a meet-and-confer.

Consequence

See outcome