{"id":144507,"date":"2026-02-19T17:13:33","date_gmt":"2026-02-20T01:13:33","guid":{"rendered":"https:\/\/xira.com\/p\/2026\/02\/19\/am-law-100-firm-accused-of-filing-brief-riddled-with-ai-hallucinations-again\/"},"modified":"2026-02-19T17:13:33","modified_gmt":"2026-02-20T01:13:33","slug":"am-law-100-firm-accused-of-filing-brief-riddled-with-ai-hallucinations-again","status":"publish","type":"post","link":"https:\/\/xira.com\/p\/2026\/02\/19\/am-law-100-firm-accused-of-filing-brief-riddled-with-ai-hallucinations-again\/","title":{"rendered":"Am Law 100 Firm Accused Of Filing Brief Riddled With AI Hallucinations\u2026 AGAIN!"},"content":{"rendered":"

Not every mistake is attributable to an AI hallucination. But once a firm suffers a couple admonishments from the court \u2014 including one that cost the firm over $50K to make right<\/a> \u2014 its lawyers have to redouble their effort to keep every filing above reproach. Because the moment anything looks off, opposing counsel will wonder if it\u2019s the product of AI run amok and lax oversight. <\/p>\n

And the court isn\u2019t likely to give the accused firm the benefit of the doubt.<\/p>\n

Gordon Rees became a cautionary example for AI hallucination mishaps after one of its attorneys submitted fabricated citations in a bankruptcy case<\/a> last summer. In Jackson Hosp. & Clinic Inc.<\/em>, a judge issued an order to show cause why sanctions shouldn\u2019t follow based upon a brief with \u201cpervasive inaccurate, misleading, and fabricated citations, quotations, and representations of legal authority.\u201d The firm reimbursed fees for lawyers inconvenienced by the error and threw itself on the mercy of the court and assured everyone that it had\u00a0updated its AI policies<\/a>\u00a0to include a \u201ccite checking policy.\u201d<\/p>\n

Fast forward to the present, and a recently filed brief in Huynh v. Redis Labs<\/em>, claims that Gordon Rees has again submitted a brief with AI hallucinations. In a motion to compel battle entering its third round after the defendant represented by Gordon Rees failed to comply with the first two orders to compel. Despite earning monetary sanctions and a warning that terminating sanctions could follow, the defendant still hadn\u2019t been deposed \u2014 canceling at the last minute attributed to a medical emergency \u2014 and the plaintiff, represented by Bach Mili LLP, filed a renewed motion. <\/p>\n

Gordon Rees submitted its opposition and, in reply, Bach Mili claims that a lot of the citations don\u2019t add up:<\/p>\n

\n

The distortions go directly to the governing standard for terminating sanctions. Defendants cite Doppes v. Bentley Motors, Inc.<\/em> to argue termination is inappropriate where a party expresses willingness to comply. (Opp. at 7.) Doppes<\/em> holds the opposite. The Court of Appeal concluded the trial court abused its discretion by refusing to impose terminating sanctions after repeated discovery violations and ineffective lesser sanctions, and directed entry of judgment as a sanction. (174 Cal.App.4th 967, 992-994.) Defendants invoke Collisson &<\/em> Kaplan v. Hartunian<\/em> for the proposition that terminating sanctions should be used sparingly, though that phrase does not appear in the opinion and the case affirmed striking the defendant\u2019s answer for \u201clawyer game playing at its worst.\u201d (Opp. at 4; 21 Cal.App.4th 1611, 1617.) They attribute to Biles v. Exxon Mobil Corp.<\/em> a definition of willfulness that does not exist. (Opp. at 5.) They cite Rail Services of America v. State Comp. Ins. Fund<\/em> for language that does not appear in the decision. (Id. at 4.) They represent Huh v. Wang<\/em> and Corns v. Miller<\/em> as excusing noncompliance based on medical emergency, though neither case stands for that proposition. These are not debatable characterizations. (Id. at 5.) They are reversals of holdings and quotations that do not exist. <\/p>\n<\/blockquote>\n

The brief doesn\u2019t explicitly say these issues were caused by AI research and drafting, but it does include the relevant local precedent holding that, \u201can attorney has a nondelegable duty to personally read and verify every cited case and that reliance on hallucinated authority renders a filing frivolous and sanctionable.\u201d<\/p>\n

\u201cDefendants\u2019 opposition is sanctionable on its face because it relies on false and misleading legal authority, misstates holdings, and fabricates quotations,\u201d Bach Mili states. \u201cThis is not aggressive advocacy or sloppy research. It is the submission of false authority to the Court in violation of counsel\u2019s most basic obligations.\u201d<\/p>\n

The reply also calls out a December 3, 2025 order in Villalovos-Gutierrez v. Pol<\/em>, where Gordon Rees earned another reprimand for AI-hallucinations. U.S. Magistrate Judge Carolyn Delaney wrote in that order:<\/p>\n

\n

In more than one other instance, defendant\u2019s case citations do not support the specific explanatory phrase presented alongside the citation. Counsel shall not file or otherwise present to the court any documents which contain AI-hallucinated citations or fictitious or non-existent legal citations. Counsel\u2019s failure to confirm the existence of, as well as the accuracy and veracity of a case or other legal citation created by an AI tool or taken from another indirect source, is a potential ground for sanctions.<\/p>\n<\/blockquote>\n

That\u2019s December. That\u2019s several months after Gordon Rees suffered their very public benchslapping in August. That\u2019s after the firm promised its updated AI policy with stricter cite checking. But a cite-checking policy only works if people follow it, and if these allegations are accurate, whatever internal reforms the firm implemented either aren\u2019t being followed or aren\u2019t enough.<\/p>\n

Also, according to the reply, the partner on Villalovos-Gutierrez<\/em> was\u2026 the exact same partner in this case<\/em>. <\/p>\n

That doesn\u2019t mean these cites are necessarily AI-generated. Taking careful liberties with the meaning of cases is a time-honored tradition that predates ChatGPT by a few centuries.<\/p>\n

But a firm that\u2019s already been dinged for hallucinations, and a partner who has already been separately<\/em> dinged for hallucinations, filing a brief with a bunch of arguably incorrect cites? It does not take a machine learning scientist to think AI is at least arguably involved.<\/p>\n

And that\u2019s the real problem for Gordon Rees \u2014 or any firm caught in a hallucination kerfuffle \u2014 right now. Whether any specific citation was generated by AI \u2014 indeed, whether any specific citation is even wrong<\/em> as opposed to merely debatable \u2014 opposing counsel now has every incentive to scrutinize any citation out of the firm with a jeweler\u2019s loupe. The damage of a hallucination incident spills over into all of the firm\u2019s litigation efforts and it will take a long time to repair that harm.<\/p>\n

Earlier<\/strong>: Biglaw Firm \u2018Profoundly Embarrassed\u2019 After Submitting Court Filing Riddled With AI Hallucinations<\/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

The post Am Law 100 Firm Accused Of Filing Brief Riddled With AI Hallucinations\u2026 AGAIN!<\/a> appeared first on Above the Law<\/a>.<\/p>\n

\"\"<\/figure>\n

Not every mistake is attributable to an AI hallucination. But once a firm suffers a couple admonishments from the court \u2014 including one that cost the firm over $50K to make right<\/a> \u2014 its lawyers have to redouble their effort to keep every filing above reproach. Because the moment anything looks off, opposing counsel will wonder if it\u2019s the product of AI run amok and lax oversight. <\/p>\n

And the court isn\u2019t likely to give the accused firm the benefit of the doubt.<\/p>\n

Gordon Rees became a cautionary example for AI hallucination mishaps after one of its attorneys submitted fabricated citations in a bankruptcy case<\/a> last summer. In Jackson Hosp. & Clinic Inc.<\/em>, a judge issued an order to show cause why sanctions shouldn\u2019t follow based upon a brief with \u201cpervasive inaccurate, misleading, and fabricated citations, quotations, and representations of legal authority.\u201d The firm reimbursed fees for lawyers inconvenienced by the error and threw itself on the mercy of the court and assured everyone that it had\u00a0updated its AI policies<\/a>\u00a0to include a \u201ccite checking policy.\u201d<\/p>\n

Fast forward to the present, and a recently filed brief in Huynh v. Redis Labs<\/em>, claims that Gordon Rees has again submitted a brief with AI hallucinations. In a motion to compel battle entering its third round after the defendant represented by Gordon Rees failed to comply with the first two orders to compel. Despite earning monetary sanctions and a warning that terminating sanctions could follow, the defendant still hadn\u2019t been deposed \u2014 canceling at the last minute attributed to a medical emergency \u2014 and the plaintiff, represented by Bach Mili LLP, filed a renewed motion. <\/p>\n

Gordon Rees submitted its opposition and, in reply, Bach Mili claims that a lot of the citations don\u2019t add up:<\/p>\n

\n

The distortions go directly to the governing standard for terminating sanctions. Defendants cite Doppes v. Bentley Motors, Inc.<\/em> to argue termination is inappropriate where a party expresses willingness to comply. (Opp. at 7.) Doppes<\/em> holds the opposite. The Court of Appeal concluded the trial court abused its discretion by refusing to impose terminating sanctions after repeated discovery violations and ineffective lesser sanctions, and directed entry of judgment as a sanction. (174 Cal.App.4th 967, 992-994.) Defendants invoke Collisson &<\/em> Kaplan v. Hartunian<\/em> for the proposition that terminating sanctions should be used sparingly, though that phrase does not appear in the opinion and the case affirmed striking the defendant\u2019s answer for \u201clawyer game playing at its worst.\u201d (Opp. at 4; 21 Cal.App.4th 1611, 1617.) They attribute to Biles v. Exxon Mobil Corp.<\/em> a definition of willfulness that does not exist. (Opp. at 5.) They cite Rail Services of America v. State Comp. Ins. Fund<\/em> for language that does not appear in the decision. (Id. at 4.) They represent Huh v. Wang<\/em> and Corns v. Miller<\/em> as excusing noncompliance based on medical emergency, though neither case stands for that proposition. These are not debatable characterizations. (Id. at 5.) They are reversals of holdings and quotations that do not exist. <\/p>\n<\/blockquote>\n

The brief doesn\u2019t explicitly say these issues were caused by AI research and drafting, but it does include the relevant local precedent holding that, \u201can attorney has a nondelegable duty to personally read and verify every cited case and that reliance on hallucinated authority renders a filing frivolous and sanctionable.\u201d<\/p>\n

\u201cDefendants\u2019 opposition is sanctionable on its face because it relies on false and misleading legal authority, misstates holdings, and fabricates quotations,\u201d Bach Mili states. \u201cThis is not aggressive advocacy or sloppy research. It is the submission of false authority to the Court in violation of counsel\u2019s most basic obligations.\u201d<\/p>\n

The reply also calls out a December 3, 2025 order in Villalovos-Gutierrez v. Pol<\/em>, where Gordon Rees earned another reprimand for AI-hallucinations. U.S. Magistrate Judge Carolyn Delaney wrote in that order:<\/p>\n

\n

In more than one other instance, defendant\u2019s case citations do not support the specific explanatory phrase presented alongside the citation. Counsel shall not file or otherwise present to the court any documents which contain AI-hallucinated citations or fictitious or non-existent legal citations. Counsel\u2019s failure to confirm the existence of, as well as the accuracy and veracity of a case or other legal citation created by an AI tool or taken from another indirect source, is a potential ground for sanctions.<\/p>\n<\/blockquote>\n

That\u2019s December. That\u2019s several months after Gordon Rees suffered their very public benchslapping in August. That\u2019s after the firm promised its updated AI policy with stricter cite checking. But a cite-checking policy only works if people follow it, and if these allegations are accurate, whatever internal reforms the firm implemented either aren\u2019t being followed or aren\u2019t enough.<\/p>\n

Also, according to the reply, the partner on Villalovos-Gutierrez<\/em> was\u2026 the exact same partner in this case<\/em>. <\/p>\n

That doesn\u2019t mean these cites are necessarily AI-generated. Taking careful liberties with the meaning of cases is a time-honored tradition that predates ChatGPT by a few centuries.<\/p>\n

But a firm that\u2019s already been dinged for hallucinations, and a partner who has already been separately<\/em> dinged for hallucinations, filing a brief with a bunch of arguably incorrect cites? It does not take a machine learning scientist to think AI is at least arguably involved.<\/p>\n

And that\u2019s the real problem for Gordon Rees \u2014 or any firm caught in a hallucination kerfuffle \u2014 right now. Whether any specific citation was generated by AI \u2014 indeed, whether any specific citation is even wrong<\/em> as opposed to merely debatable \u2014 opposing counsel now has every incentive to scrutinize any citation out of the firm with a jeweler\u2019s loupe. The damage of a hallucination incident spills over into all of the firm\u2019s litigation efforts and it will take a long time to repair that harm.<\/p>\n

Earlier<\/strong>: Biglaw Firm \u2018Profoundly Embarrassed\u2019 After Submitting Court Filing Riddled With AI Hallucinations<\/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","protected":false},"excerpt":{"rendered":"

Not every mistake is attributable to an AI hallucination. But once a firm suffers a couple admonishments from the court \u2014 including one that cost the firm over $50K to make right \u2014 its lawyers have to redouble their effort to keep every filing above reproach. Because the moment anything looks off, opposing counsel will […]<\/p>\n","protected":false},"author":3,"featured_media":144503,"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-144507","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-above_the_law"],"jetpack_featured_media_url":"https:\/\/i0.wp.com\/xira.com\/p\/wp-content\/uploads\/2026\/02\/Headshot-300x200-30TTaN.jpg?fit=300%2C200&ssl=1","jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/posts\/144507","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=144507"}],"version-history":[{"count":0,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/posts\/144507\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/media\/144503"}],"wp:attachment":[{"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/media?parent=144507"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/categories?post=144507"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/xira.com\/p\/wp-json\/wp\/v2\/tags?post=144507"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}