{"id":128826,"date":"2025-07-29T15:50:13","date_gmt":"2025-07-29T23:50:13","guid":{"rendered":"https:\/\/xira.com\/p\/2025\/07\/29\/biglaw-ai-apocalypse-brews-as-one-fake-case-turns-into-litany-of-false-cites\/"},"modified":"2025-07-29T15:50:13","modified_gmt":"2025-07-29T23:50:13","slug":"biglaw-ai-apocalypse-brews-as-one-fake-case-turns-into-litany-of-false-cites","status":"publish","type":"post","link":"https:\/\/xira.com\/p\/2025\/07\/29\/biglaw-ai-apocalypse-brews-as-one-fake-case-turns-into-litany-of-false-cites\/","title":{"rendered":"Biglaw AI Apocalypse Brews As One Fake Case Turns Into Litany Of False Cites"},"content":{"rendered":"
\"\"
<\/figcaption><\/figure>\n

After confessing the firm submitted a post-trial motion citing a non-existent case helpfully supplied by ChatGPT<\/a>, Goldberg Segalla cut ties with partner Danielle Malaty. Presumably, the firm hoped that would be the end of it.<\/p>\n

But it seems that filing was just the amuse-bouche!<\/p>\n

Upon realizing that Goldberg Segalla had inserted one fake citation, the plaintiffs wondered if it might be worth another quick glance at the docket. You know\u2026 because most lawyers enjoy chasing down important research instead of shrugging it off as good enough. A newly filed motion for sanctions<\/a> in Jordan v. Chicago Housing Authority<\/em> suggests the plaintiffs made the right move, outlining a systemic AI hallucination jamboree going well beyond an errant cite to the fictitious Mack v. Anderson<\/em> case that started this ball rolling.<\/p>\n

An Illinois jury awarded $24.1 million in this pediatric lead poisoning case where two children were left with irreversible brain damage after years of litigation. Rather than owning up to that outcome, the Chicago Housing Authority (CHA to its friends) and Goldberg Segalla opted to litigate the verdict into oblivion. It was the motion asking the judge to set aside the verdict that first uncovered that the Housing Authority\u2019s legal arsenal might be cobbled together from AI-generated fan fiction.<\/p>\n

Over the course of five days, having only the opportunity to review a slice of the docket, the plaintiffs discovered that when it comes to hallucinated research, not unlike Lay\u2019s Potato Chips, betcha can\u2019t cite just one.<\/p>\n

\n

Following the Court\u2019s July 17, 2025 hearing which primarily focused on the CHA\u2019s citation to the fabricated case of Mack v. Anderson<\/em>, Plaintiffs\u2019 counsel more closely reviewed additional pleadings filed by Goldberg Segalla on behalf of the CHA. Based on that additional review, it is evident that the CHA\u2019s misrepresentations, false claims, and reliance on non-existent case law were not limited to a single citation \u2013 or even a single pleading. Rather, now unearthed is a pattern of repetitive and continuous misrepresentations to the Court. The misrepresentations identified to date are addressed below. When applied to the appropriate legal standard, it is clear that severe sanctions are warranted.<\/p>\n<\/blockquote>\n

Digging into the pervasiveness of the illusion, plaintiffs checked out the Mid-Trial Offer of Proof that Goldberg Segalla showed to the expert witness and discovered \u201cnumerous faulty case citations, fabricated case quotations, and another non-existent case.\u201d Here\u2019s part of a table included with the sanctions motion:<\/p>\n

\"\"
<\/figcaption><\/figure>\n

It goes on like that for another page. And Mack v. Anderson<\/em> shows up in there too.<\/p>\n

The mistakes aren\u2019t even limited to filings that matter<\/em>! Way back in February, Goldberg Segalla filed a motion seeking an extension that plaintiffs weren\u2019t even interested in contesting \u2014 which explains why no one bothered to give it much attention before now. Guess what happened?<\/p>\n

\n

And while the relief sought in the CHA\u2019s Motion for Extension was neither extraordinary nor even contested, Plaintiffs have revisited that pleading too for a closer review. In a turn of ironic absurdity, the CHA\u2019s Motion for Extension \u2013 seeking additional time to perform the requisite legal research to address the \u201csignificant legal questions\u201d that the CHA anticipated in its Post-Trial Motion \u2013 is premised on faulty and invented legal authority.<\/p>\n<\/blockquote>\n

Stop. No. Come on, people.<\/p>\n

\"\"
<\/figcaption><\/figure>\n

And, again, there are a couple more items in this table too. <\/p>\n

Not even the post-trial motion that started this all escaped without further scrutiny with the plaintiffs identifying \u201cextensive and far reaching misrepresentations \u2013 including outright falsehoods and problematic legal citations\u201d beyond the Mack<\/em> case. That table runs from page 16 to page 20 and includes alleged misrepresentations of cases and the factual record of the instant matter alike. <\/p>\n

Most of the cases so far focus on hapless lawyers using AI for legal research and then never checking it (or, the new excuse of using another tech tool to \u201ccheck\u201d for mistakes that doesn\u2019t end up working \u2014 possibly through operator error<\/a>). But it can potentially create factual hallucinations too if someone shoves a transcript into the bot and asks it to pull information that it then mischaracterizes.<\/p>\n

We just saw an Alabama federal court finally get tough on a hallucination case, kicking the Butler Snow lawyers off the case<\/a> \u2014 over the objections of the client, no less! \u2014 while heaping considerable scorn on the most senior attorneys who tried to avoid responsibility by claiming that they\u2019re too far above the mundane task of checking someone else\u2019s work. Likewise in this case, the sanctions motion asserts that while the CHA threw Malaty under the CTA bus as the partner responsible for inserting the Mack<\/em> case, the rest of the senior Goldberg Segalla team bear responsibility for checking the filings too.<\/p>\n

\n

This case is no longer about a single faulty citation that was the result of a \u201cwhoopsie\u201d by a lawyer toying with new technology. This is now a case about successively filed pleadings that were fundamentally flawed based on the fact that they relied on non-existent or misrepresented caselaw. This is a case that also involves patently false misrepresentations about what actually happened at a trial of great public importance. This is a case where even in the face of inexcusable conduct, Goldberg Segalla and the CHA still press forward with defective pleadings in an attempt to throw out the jury\u2019s verdicts.<\/p>\n<\/blockquote>\n

As Judge Manasco wrote in the Butler Snow case of the AI hallucination sanctions to date, \u201cIf fines and public embarrassment were effective deterrents, there would not be so many cases to cite.\u201d This judge in this case might soon join Judge Manasco\u2019s sentiment. <\/p>\n

(Full sanctions motion on the next page\u2026)<\/em><\/p>\n

Earlier<\/strong>: Partner Who Wrote About AI Ethics, Fired For Citing Fake AI Cases<\/a>
Court Kicks Lawyers Off Case After Finding Fake AI Cases In Filings<\/a><\/p>\n

\n

\"Headshot\"Joe Patrice<\/a>\u00a0is a senior editor at Above the Law and co-host of Thinking Like A Lawyer<\/a>. Feel free to\u00a0email<\/a> any tips, questions, or comments. Follow him on\u00a0Twitter<\/a>\u00a0or Bluesky<\/a> if you\u2019re interested in law, politics, and a healthy dose of college sports news. Joe also serves as a Managing Director at RPN Executive Search<\/a>.<\/em><\/strong><\/p>\n<\/p>\n

The post Biglaw AI Apocalypse Brews As One Fake Case Turns Into Litany Of False Cites<\/a> appeared first on Above the Law<\/a>.<\/p>\n

\"\"
<\/figcaption><\/figure>\n

After confessing the firm submitted a post-trial motion citing a non-existent case helpfully supplied by ChatGPT<\/a>, Goldberg Segalla cut ties with partner Danielle Malaty. Presumably, the firm hoped that would be the end of it.<\/p>\n

But it seems that filing was just the amuse-bouche!<\/p>\n

Upon realizing that Goldberg Segalla had inserted one fake citation, the plaintiffs wondered if it might be worth another quick glance at the docket. You know\u2026 because most lawyers enjoy chasing down important research instead of shrugging it off as good enough. A newly filed motion for sanctions<\/a> in Jordan v. Chicago Housing Authority<\/em> suggests the plaintiffs made the right move, outlining a systemic AI hallucination jamboree going well beyond an errant cite to the fictitious Mack v. Anderson<\/em> case that started this ball rolling.<\/p>\n

An Illinois jury awarded $24.1 million in this pediatric lead poisoning case where two children were left with irreversible brain damage after years of litigation. Rather than owning up to that outcome, the Chicago Housing Authority (CHA to its friends) and Goldberg Segalla opted to litigate the verdict into oblivion. It was the motion asking the judge to set aside the verdict that first uncovered that the Housing Authority\u2019s legal arsenal might be cobbled together from AI-generated fan fiction.<\/p>\n

Over the course of five days, having only the opportunity to review a slice of the docket, the plaintiffs discovered that when it comes to hallucinated research, not unlike Lay\u2019s Potato Chips, betcha can\u2019t cite just one.<\/p>\n

\n

Following the Court\u2019s July 17, 2025 hearing which primarily focused on the CHA\u2019s citation to the fabricated case of Mack v. Anderson<\/em>, Plaintiffs\u2019 counsel more closely reviewed additional pleadings filed by Goldberg Segalla on behalf of the CHA. Based on that additional review, it is evident that the CHA\u2019s misrepresentations, false claims, and reliance on non-existent case law were not limited to a single citation \u2013 or even a single pleading. Rather, now unearthed is a pattern of repetitive and continuous misrepresentations to the Court. The misrepresentations identified to date are addressed below. When applied to the appropriate legal standard, it is clear that severe sanctions are warranted.<\/p>\n<\/blockquote>\n

Digging into the pervasiveness of the illusion, plaintiffs checked out the Mid-Trial Offer of Proof that Goldberg Segalla showed to the expert witness and discovered \u201cnumerous faulty case citations, fabricated case quotations, and another non-existent case.\u201d Here\u2019s part of a table included with the sanctions motion:<\/p>\n

\"\"
<\/figcaption><\/figure>\n

It goes on like that for another page. And Mack v. Anderson<\/em> shows up in there too.<\/p>\n

The mistakes aren\u2019t even limited to filings that matter<\/em>! Way back in February, Goldberg Segalla filed a motion seeking an extension that plaintiffs weren\u2019t even interested in contesting \u2014 which explains why no one bothered to give it much attention before now. Guess what happened?<\/p>\n

\n

And while the relief sought in the CHA\u2019s Motion for Extension was neither extraordinary nor even contested, Plaintiffs have revisited that pleading too for a closer review. In a turn of ironic absurdity, the CHA\u2019s Motion for Extension \u2013 seeking additional time to perform the requisite legal research to address the \u201csignificant legal questions\u201d that the CHA anticipated in its Post-Trial Motion \u2013 is premised on faulty and invented legal authority.<\/p>\n<\/blockquote>\n

Stop. No. Come on, people.<\/p>\n

\"\"
<\/figcaption><\/figure>\n

And, again, there are a couple more items in this table too. <\/p>\n

Not even the post-trial motion that started this all escaped without further scrutiny with the plaintiffs identifying \u201cextensive and far reaching misrepresentations \u2013 including outright falsehoods and problematic legal citations\u201d beyond the Mack<\/em> case. That table runs from page 16 to page 20 and includes alleged misrepresentations of cases and the factual record of the instant matter alike. <\/p>\n

Most of the cases so far focus on hapless lawyers using AI for legal research and then never checking it (or, the new excuse of using another tech tool to \u201ccheck\u201d for mistakes that doesn\u2019t end up working \u2014 possibly through operator error<\/a>). But it can potentially create factual hallucinations too if someone shoves a transcript into the bot and asks it to pull information that it then mischaracterizes.<\/p>\n

We just saw an Alabama federal court finally get tough on a hallucination case, kicking the Butler Snow lawyers off the case<\/a> \u2014 over the objections of the client, no less! \u2014 while heaping considerable scorn on the most senior attorneys who tried to avoid responsibility by claiming that they\u2019re too far above the mundane task of checking someone else\u2019s work. Likewise in this case, the sanctions motion asserts that while the CHA threw Malaty under the CTA bus as the partner responsible for inserting the Mack<\/em> case, the rest of the senior Goldberg Segalla team bear responsibility for checking the filings too.<\/p>\n

\n

This case is no longer about a single faulty citation that was the result of a \u201cwhoopsie\u201d by a lawyer toying with new technology. This is now a case about successively filed pleadings that were fundamentally flawed based on the fact that they relied on non-existent or misrepresented caselaw. This is a case that also involves patently false misrepresentations about what actually happened at a trial of great public importance. This is a case where even in the face of inexcusable conduct, Goldberg Segalla and the CHA still press forward with defective pleadings in an attempt to throw out the jury\u2019s verdicts.<\/p>\n<\/blockquote>\n

As Judge Manasco wrote in the Butler Snow case of the AI hallucination sanctions to date, \u201cIf fines and public embarrassment were effective deterrents, there would not be so many cases to cite.\u201d This judge in this case might soon join Judge Manasco\u2019s sentiment. <\/p>\n

(Full sanctions motion on the next page\u2026)<\/em><\/p>\n

Earlier<\/strong>: Partner Who Wrote About AI Ethics, Fired For Citing Fake AI Cases<\/a>
Court Kicks Lawyers Off Case After Finding Fake AI Cases In Filings<\/a><\/p>\n

\n

\"Headshot\"Joe Patrice<\/a>\u00a0is a senior editor at Above the Law and co-host of Thinking Like A Lawyer<\/a>. Feel free to\u00a0email<\/a> any tips, questions, or comments. Follow him on\u00a0Twitter<\/a>\u00a0or Bluesky<\/a> if you\u2019re interested in law, politics, and a healthy dose of college sports news. Joe also serves as a Managing Director at RPN Executive Search<\/a>.<\/em><\/strong><\/p>\n

1<\/strong> 2<\/a>Next \u00bb<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

After confessing the firm submitted a post-trial motion citing a non-existent case helpfully supplied by ChatGPT, Goldberg Segalla cut ties with partner Danielle Malaty. Presumably, the firm hoped that would be the end of it. But it seems that filing was just the amuse-bouche! Upon realizing that Goldberg Segalla had inserted one fake citation, the […]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"","ping_status":"","sticky":false,"template":"","format":"standard","meta":{"_et_pb_use_builder":"","_et_pb_old_content":"","_et_gb_content_width":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[16],"tags":[],"class_list":["post-128826","post","type-post","status-publish","format-standard","hentry","category-above_the_law"],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/posts\/128826","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/comments?post=128826"}],"version-history":[{"count":0,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/posts\/128826\/revisions"}],"wp:attachment":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/media?parent=128826"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/categories?post=128826"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/tags?post=128826"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}