AI Hallucination Cases Tracker: AI and non-AI fabricated/false citations (Suspected or Confirmed)

AI hallucination cases can, and do, reach real courtrooms and have real consequences. However, there is some dispute about the correct phrasing of this phenomenon:

“…Although the termed used in relation to erroneously generated references by Al is "hallucinations", this is a term which seeks to legitimise the use of Al. More properly, such erroneously generated references are simply fabricated, fictional, false, fake and as such could be misleading...”
JML Rose Pty Ltd v Jorgensen (No 3) [2025] FCA 976 (Federal Court of Australia, 19 August 2025)

Before you use this tracker

Looking for the UK cases first?

This page is the international AI Hallucination Cases Tracker. For the dedicated UK-only tracker, use the link below for the fastest route.

Most readers looking for UK case law should start with the UK tracker. The international tracker continues below for comparative and overseas material.

Key Takeaway

This public-facing international tracker records public references to suspected or confirmed AI hallucination cases and other suspected or confirmed incidents of fabricated/false citations in court judgments, tribunal decisions and legal proceedings worldwide. Inclusion in this tracker does not mean that any named person, lawyer, party or court necessarily used AI, was suspected of using AI, acted improperly, or was found to have done so. It means only that the public source records, raises or discusses an issue concerning AI hallucinations, fabricated/false citations, or something similar.

The fuller private tracker, available only by request, contains deeper research including the false citations themselves, whether judges repeated them in judgments, the types of fabricated or false material, whether they concern case law, legislation or something else, who discovered them, whether the issue involved litigants in person/pro se or lawyers, the reasons given, and any aggravating or mitigating features. This tracker is always evolving and cases may be added or removed at any point.

Tracker Status: Active/Monitoring
Publication Date: 16 May 2025
Last Verified: 30 May 2026
Latest Case Chronologically: Blanes v Steller Jay Academy Inc
Latest Legal Article: 64 UK Cases of Hallucinated Citations (suspected or confirmed)
Other AI Legal Trackers: AI Law Trackers Hub
Author and Contact: Matthew Lee (Barrister) click here for details.

AI Hallucination Cases Tracker

Ad/Marketing Communication

UK‑based legal commentary and comparative analysis of international case law on AI related legal issues. This AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations) forms part of lecturing/teaching law and writing/editing law articles/reports and is communicated solely in connection with promoting or advertising Matthew Lee’s practice. Not legal advice. Not Direct/Public Access. All instructions via clerks at Doughty Street Chambers.

16 May 20265 Update on AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations)

Thank you for your patience while I update the AI Hallucinations Cases Tracker (AI and non-AI fabricated/false citations).
The latest entries and analyses are being added shortly. In the meantime, enter your email below to be notified when the update is complete and to receive regular insights and case summaries.

What you can see

You will see two things below: the AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations) and a set of Charts/Diagrams. The tracker lists the case reference (neutral citation), a link to the public judgment, and a short extract from that judgment.

What the Charts Show

The charts below give a rough picture of the data I’m currently analysing on AI and non-AI fabricated/false citations. They offer early insights into some of the key questions I’m exploring, including:

  • Did the judge cite the fabricated or false citation within the judgment?
  • What types of AI and non-AI fabricated/false citations are finding their way into court?
  • Are these AI and non-AI fabricated/false citations referring to case law, legislation, or something else?
  • Who is discovering the AI and non-AI fabricated/false citations?
  • Is this mainly occurring with litigants in person (pro se) or with lawyers?
  • What reasons are given for the AI and non-AI fabricated/false citations?
  • What features are aggravating or mitigating?

What’s in the Vault (My Unpublished Private Tracker)

These visuals are powered by my private research, which is not included in the publicly available AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations) below. This private research contains deeper analysis, richer tagging, broader categories, detailed timelines and considerable detail on fabricated/false citations. It contains cases which are not on the public tracker.

I do not publish the underlying databases or research publicly. If you wish to discuss access to my private research, please contact my clerks (details above)

Important Note

This tracker is part of my ongoing research. It takes time to build and is updated frequently as I work through new judgments and revisit the historic. For further analysis of these cases, I would suggest reading my regular commentary on AI Hallucinations (AI and non-AI fabricated/false citations) cases globally. The latest is available [here]. Most cases are from the USA, but this is an international issue.

The aim of this AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations) is to gather broad data about how hallucinations, fabricated citations, whether by AI or otherwise, proven or just alleged, are appearing in courts and reports. As set out above, I am interested in questions such as: Why is this happening? What types of hallucinations are occurring? What reasons are given? What mitigating or aggravating features are raised? And whether judges themselves cite these errors in their authentic judgments? I want to understand the broader international picture to advance AI law, an important area of my legal practice in England and Wales.

Judgments do not all describe these issues in the same way, and they do not always fit neatly within a label. To spot patterns and make study easier, I group what is recorded, advanced, or alleged into broad categories. This means the tracker will not always match the exact wording of the judgment and it may be incomplete or contain errors. For the detail in any particular case, always check the official judgment via the hyperlink. If the hyperlink takes you to one of my legal articles on this blog, you will be able to access the judgment from that legal article.

I also use AI tools and other online resources to help organise and maintain this AI Hallucination Cases Tracker (AI and non-AI fabricated/false citations). For that reason, and because the task involves categorising complex material, you should always verify details against the judgment itself. If you notice anything that looks inaccurate, please let me know and I will review and update.

How To Read the Columns and the Charts

Actor
Based on the judgment, I record whether it was a lawyer, a litigant in person, or another participant connected with the alleged error. Different judgments use different wording, so I seek to place them into consistent groups to make the data comparable.

Hallucination Type
I have grouped the most common types of AI and non-AI fabricated/false citations into eight categories, explained in detail in a separate article. Where something does not fit perfectly, I place it in the closest type so it can be counted and compared across judgments.

Reasons
This records reasons either found by the court or advanced by a party. They are grouped into broad categories such as “time pressure” or “lack of training” so that different explanations can be studied together. Always check the judgment for the precise detail, as reasons are often more complex than the summary category suggests.

Mitigation
This includes both mitigating factors the court accepted and those advanced by a party, such as “acted honestly” or “tried to put it right”. They are grouped so we can see the range of issues raised across cases and compare how courts respond. Specific mitigation is always more nuanced than the summary (always check the judgment for the full detail).

Aggravation
This includes aggravating factors noted by the court or advanced in submissions, such as “repeated incident” or “ignoring guidance”. They are grouped into categories for comparison. Again, for the exact findings, always refer to the judgment.

Cited Fake Case
A simple yes/no marker showing whether the judge cited a hallucinated case/fabricated citation or principle within the judgment itself. Why this issue matters is explained here.

Research Upload in Progress – Thank You for Bearing with Me!

This tracker is being updated in real time, so some parts may look unfinished for a few days, so please frequently check in. There’s also plenty to explore in the meantime:

  • The UK Position: the UK incidents are reported separately here.
  • What are AI Hallucination Cases and the 8 Types: if you’d like to understand what a legal hallucination actually is and the different ways it appears, take a look at the 8 types I’ve identified in this article. These form the of my AI hallucination cases trackers.
  • Weekly write-ups (International): every week I try and write up the most recent AI hallucination cases. The latest is available [here]. Most case are from the USA, but this is an international issue.
  • AI Law Trackers and Databases Hub: Have a look at the other AI issues I write about here.
  • Popular Posts: read all about this project and popular posts/AI trackers here.
  • Check out the FAQ below for common Questions
  • Subscribe: I send regular updates from Substack here direct to your email (It’s FREE). Be the first to receive important updates in AI law.

Thank you for your patience – the full launch is coming very soon. In the meantime, dive into the existing resources and see how the field is already evolving.

Key Stats Line & Charts

Total entries: [TBC] Last updated: [22 November 2025].

AI Hallucination Cases Tracker Under Construction

DateCaseJudicial Quotes
28 May 2026Blanes v. Stellers Jay Academy Inc.I find these authorities are likely “hallucinations,” meaning false or misleading results generated by artificial intelligence.
27 May 2026Innocent v. Meraki Installers, LLC"This appeal follows a final judgment entered in favor of the Appellee in a lawsuit for breach of contract and foreclosure of a construction lien. We affirm without comment on all issues. We "write briefly, however, to address concerns regarding multiple quotations from the trial transcript contained in Appellant’s initial brief that do not appear to be foundanywhere in the actual trial transcript or otherwise in the Record. In consideration of the arguments made on this point in the parties’ briefs, as well as during oral argument, we refer this matter to the Florida Bar for appropriate action.
27 May 2026Eclectic Synergy, LLC v. Seredin"We denied the “emergency” motion for stay,1 and issued an order requiring counsel to show cause why sanctions should not be imposed because the petition appears AI-generated and raises frivolous arguments, misstates the law, and cites non-existent caselaw."
27 May 2026Robert Hinton Avery v. Danielle Beauzil"This argument misstates the law, and the cited cases do not support the argument...The law does not support petitioner’s argument at all. These types of AI-hallucinated arguments are just as egregious as a citation to non-existent law...."
27 May 2026Williamson v. Meyers (derivatively on behalf of Equinix, Inc.)"In reviewing Plaintiffs briefing, the Court identified at least one existence where Plaintiff had cited to a non-existent authority and brought this issue to Plaintiffs attention. Afterinvestigating, Plaintiff conceded that this fictitious citation was most likely the result of artificial intelligence ("Al"). The Court has not considered any of Plaintiffs contentions, to the extent that they rely on fabricated authority, and will consider whether any other action is necessary."
27 May 2026Christ Apostolic Temple, Inc., Dwight Reed and Jordan Reed v. Demetrius Sinegal, et al."...briefs contain citations to cases that do not exist or do not stand for the proposition for which they are cited. This suggests the possibility that he used generative artificial intelligence to prepare his briefs. If that is the case, we again “stress that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings."
27 May 2026Chen v. The Owners, Strata Plan LMS3094 "I find these are likely “hallucinations”, meaning false or misleading results generated by artificial intelligence. ...While I havereviewed all of ... submissions and evidence, I have only addressed what is relevant in my decision."
27 May 2026State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves"There is nothing inherently problematic with the use of generative artificial intelligence in preparing legal materials, so long as attorneys abide by their duty to protect client confidentiality and recall their sacred duty to verify the pleadings they sign. The careless use of generative artificial intelligence to "save time" by not independently confirming citations is instead a waste of judicial resources and opposing party's time and money. It also damages the integrity and credibility of the legal system. Human diligence and review is required to ensure content and accuracy of filed documents. Signing pleadings that contain citations from generative AI that have not been verified shows a reckless disregard for the truth and an indifference to accuracy."
18 May 2026Anthony Malcolm Cork & Anor v Mark Smith
Neutral Citation Number[2026] EWHC 1199 (Ch)
95. I do not intend to set out the words of the President in Ayinde again but it will be clear from what she said that legal professionals bear ultimate responsibility for their work and cannot outsource the process of legal research or of legal reasoning to an AI. It is a tool to be used with caution. AI has the potential to be wholly unreliable. AI may of course provide a jumping off point for research and legal reasoning but it does not, at least at present, do away with the need for proper research and thought on the part of a legal professional, even a very junior legal professiona
16 May 2026Jeffs v London Borough of Lewisham“32…(b) The Applicant has misunderstood the law and relied on inaccurate statements which the Tribunal understands to have originated from AI hallucinations which included false quotes of legislation and cases that were not relevant or did not exist.”
14 May 2026Rodney -v- Gee’z Micro Bar"It is important that there is a public record of this incident should anything remotely similar occur again involving [redacted firm] or these solicitors. I therefore direct that a transcript of this judgment be prepared at public expense and be published on the Judiciary website. A copy shall be sent to the Solicitors Regulation Authority alongside the witness statements filed by both solicitors and my order of 5 March 2026."
6 May 2026Rafique v The Commissioners for HMRC [2026] UKFTT 673 100. While litigants in person in the FTT are (entirely appropriately) given a greater degree of latitude in their conduct of the proceedings than represented parties, no person has immunity from sanction when committing a serious breach of court or tribunal rules. That is well demonstrated in Olsen v Finansiel Stabilitet A/S [2025] EWHC 42 (KB) where the High Court only “narrowly and somewhat reluctantly” decided against causing a summons for contempt of court to be issued to two elderly litigants in person who had provided a fabricated citation to the court.
5 May 2026Tuyunuklu v Akmal [2026] UKUT 17416. In considering the parties’ arguments I start from two propositions of law. The first is that Rakusen v Jepsen is not authority for the idea that [redacted principle]. The Supreme Court did not say that. From references to AI in the transcript I wonder if the appellant was misled by an AI hallucination. Whatever the reason, his point about Rakusen v Jepsen is without foundation
11 Mar 2026Setu Kamal v Tax Policy Associates Ltd & Anor184. At a more granular level, the Defendants object to the variety of different addresses, in different jurisdictions, [claimant] has used on his claim form, particulars of claim, application notices and witness statement. They object to his imposition of arbitrary and oppressive deadlines for responses after long periods of delay. They object to a range of features of his correspondence including misapplying the ‘without prejudice’ designation to letters containing no settlement proposals, and the deployment of AI-generated ‘hallucinatory’ references to non-existent cases causing unnecessary effort in cross-checking (there being already a growing jurisprudence of court deprecation of this phenomenon, including in exercise of the Hamid jurisdiction – see R (Ayinde) v Haringey LBC [2025] EWHC 1383 (Admin)).
5 Mar 2026Re A, B, C, D (Extension of assessment; Use of AI: hallucinations)It is the duty to the court owed by [Representative} as a litigant in person to ensure that the cases cited in legal argument are genuine and provide authority for the proposition advance with which I am concerned. She accepts that she did not do so, and apologises. She says that the mistakes were unintentional, and seeks to justify herself by saying the main authority upon which she relied was sent to me (as it was). Having heard from her, and read her submissions, I absolve her of any intention to mislead the court, but remain concerned that [Representative] minimises the seriousness of misleading the court and goes so far as to assert that criticising use of AI risks setting a harmful precedent for disabled litigants in person and will discourage access to justice.

The Original AI Hallucination Cases Tracker

My original public facing AI hallucination cases tracker which had the title “AI hallucination cases can, and do, reach real courtrooms and have real consequences” has now been archived. If you would like to see it for any reason please contact me through my clerks. The information below was related to that tracker and I keep it here for reference.

What the Original AI Hallucination Cases Tracker was for.

Generative-AI tools sometimes invent case citations, statutes, articles or facts. When those errors slip into legal documents the consequences are serious. Sometimes elements get struck out, fines are imposed, lawyers sanctioned and in extreme cases maybe even committal proceedings launched. This page tracks publicly reported decisions and strives to be one reliable index of AI hallucination cases in live legal practice.

How to use the Original AI Hallucination Cases Tracker

  • Each row summarises one decision. You’ll see the country, the date, which AI tool was involved, a short note describing the hallucination, what was done about it or is proposed, and whether the person using AI was a lawyer, a litigant-in-person (self represented) or other.
  • Click Link in the last column to open a source it is hoped that the links will provide some authoritative source, but if it doesn’t and you are aware of one, please let us know. The best sources are usually a court website, a statutory legal archive such as BAILII, CanLII or CourtListener, or a PDF published directly by a disciplinary tribunal etc.
  • The table is searchable and sortable: type in the search box to filter by country, tool or sanction, or click any column header to sort.

Why you still need to read the original document
Although I try and check each entry carefully, this page is only a summary. The authoritative version of every decision is the one you must locate yourself. Procedures can move fast: sanctions may be appealed, recommendations can become final, costs can be varied and I may not update in time. Always read the original judgment, order or ruling and you should not rely on this table in practice, publication or teaching.

Keeping the tracker current
I try to add new AI hallucination cases as soon as they are brought to my attention. The page updates automatically because the table is managed in TablePress; whenever a new row is saved, the latest version appears here without extra work. Look for the “Last updated” line beneath the table to know when the most recent changes were made.

Scope
Not all hallucinations are confirmed. In some cases, it was merely alleged. Alleged hallucinations may be included if the allegation itself was significant to the proceeding.

Why the problem matters

  1. Accuracy is fundamental. Judges rely on counsel to supply real authorities. AI hallucination cases erode trust in written advocacy and evidence.
  2. Professional duties are evolving. Many ethics codes now say lawyers must understand the technology they use. Sanctions in these decisions often reference competence rules. This is discussed elsewhere on this blog.
  3. Public confidence is important. When headlines report AI inventing cases, the public questions the legal system’s rigour. Tracking responses across jurisdictions shows how the profession is confronting the risk.

Caution
This tracker is provided for general information only and is not legal advice. The summaries and links do not replace the official judgment, and if you wish to rely on any case you must obtain the authoritative version yourself, direct from the court, tribunal or official reporter as appropriate. Do not rely solely on the information or links shown here. Before taking any action, obtain independent, qualified legal advice.

Generative AI is evolving rapidly, and so are the legal and ethical standards surrounding its use. By following this tracker you can see how courts across the globe respond to fabricated citations, ranging from mild responses to hefty sanctions. Please keep revisiting. New decisions arrive often, reinforcing the importance of verifying sources and practising diligent, technology-aware advocacy in every jurisdiction, daily.

AI Hallucination Cases Tracker FAQ

Why are they called “Hallucinations”?

This term is commonly used, but amongst lawyers, there is some discussion about whether it is the correct expression. For example in JML Rose Pty Ltd v Jorgensen (No 3) [2025] FCA 976 (Federal Court of Australia, 19 August 2025):

“…Although the termed used in relation to erroneously generated references by Al is “hallucinations”, this is a term which seeks to legitimise the use of Al. More properly, such erroneously generated references are simply fabricated, fictional, false, fake and as such could be misleading…”

For the AI hallucination cases tracker the term “hallucinations” is maintained due to its common usage and searchability. This was the term also recently adopted in the updated AI Guidance for Judicial Office Holders:

“Hallucination: AI hallucinations are incorrect or misleading results that AI models generate. These errors can be caused by a variety of factors, including insufficient training data, the model’s statistical nature, incorrect assumptions made by the model, or biases in the data used to train the model.”

My report and link to the full guidance can be read here.

Why don’t you quote the full hallucination and the hallucinated principle, even when judges do?

I am concerned that well-intentioned judges often cite AI hallucination cases and their erroneous legal principles in full within official judgments to show the extent of the problem to those reading. However, judges may be inadvertently exacerbating the issue because those inaccuracies are being integrated into the established legal canon indirectly.

I do record in my own research the full fabricated/false citations for analysis. If you would like to discuss access to this research please contact my clerks.

Why do you often choose to remove lawyers’ names from quotations in your commentary?

I often remove the names of specific lawyers in quoted material to keep the focus on the legal reasoning, judicial comments, or case outcome rather than on individuals. Full details can be read by clicking the links to the judgment.