After confessing the agency submitted a post-trial movement citing a non-existent case helpfully supplied by ChatGPT, Goldberg Segalla minimize ties with associate Danielle Malaty. Presumably, the agency hoped that may be the tip of it.
However plainly submitting was simply the amuse-bouche!
Upon realizing that Goldberg Segalla had inserted one pretend quotation, the plaintiffs puzzled if it is likely to be price one other fast look on the docket. You understand… as a result of most attorneys take pleasure in chasing down necessary analysis as a substitute of shrugging it off as ok. A newly filed motion for sanctions in Jordan v. Chicago Housing Authority suggests the plaintiffs made the suitable transfer, outlining a systemic AI hallucination jamboree going nicely past an errant cite to the fictional Mack v. Anderson case that began this ball rolling.
An Illinois jury awarded $24.1 million on this pediatric lead poisoning case the place two youngsters have been left with irreversible mind harm after years of litigation. Fairly than proudly owning as much as that final result, the Chicago Housing Authority (CHA to its pals) and Goldberg Segalla opted to litigate the decision into oblivion. It was the movement asking the decide to put aside the decision that first uncovered that the Housing Authority’s authorized arsenal is likely to be cobbled collectively from AI-generated fan fiction.
Over the course of 5 days, having solely the chance to overview a slice of the docket, the plaintiffs found that relating to hallucinated analysis, not not like Lay’s Potato Chips, betcha can’t cite only one.
Following the Court docket’s July 17, 2025 listening to which primarily centered on the CHA’s quotation to the fabricated case of Mack v. Anderson, Plaintiffs’ counsel extra intently reviewed further pleadings filed by Goldberg Segalla on behalf of the CHA. Primarily based on that further overview, it’s evident that the CHA’s misrepresentations, false claims, and reliance on non-existent case regulation weren’t restricted to a single quotation – or perhaps a single pleading. Fairly, now unearthed is a sample of repetitive and steady misrepresentations to the Court docket. The misrepresentations recognized to this point are addressed under. When utilized to the suitable authorized normal, it’s clear that extreme sanctions are warranted.
Digging into the pervasiveness of the phantasm, plaintiffs checked out the Mid-Trial Supply of Proof that Goldberg Segalla confirmed to the knowledgeable witness and found “quite a few defective case citations, fabricated case quotations, and one other non-existent case.” Right here’s a part of a desk included with the sanctions movement:
It goes on like that for an additional web page. And Mack v. Anderson reveals up in there too.
The errors aren’t even restricted to filings that matter! Manner again in February, Goldberg Segalla filed a movement looking for an extension that plaintiffs weren’t even serious about contesting — which explains why nobody bothered to offer it a lot consideration prior to now. Guess what occurred?
And whereas the aid sought within the CHA’s Movement for Extension was neither extraordinary nor even contested, Plaintiffs have revisited that pleading too for a better overview. In a flip of ironic absurdity, the CHA’s Movement for Extension – looking for further time to carry out the requisite authorized analysis to handle the “important authorized questions” that the CHA anticipated in its Put up-Trial Movement – is premised on defective and invented authorized authority.
Cease. No. Come on, folks.
And, once more, there are a pair extra objects on this desk too.
Not even the post-trial movement that began this all escaped with out additional scrutiny with the plaintiffs figuring out “intensive and much reaching misrepresentations – together with outright falsehoods and problematic authorized citations” past the Mack case. That desk runs from web page 16 to web page 20 and consists of alleged misrepresentations of circumstances and the factual file of the moment matter alike.
Many of the circumstances up to now give attention to hapless attorneys utilizing AI for authorized analysis after which by no means checking it (or, the brand new excuse of utilizing one other tech instrument to “examine” for errors that doesn’t find yourself working — possibly through operator error). However it may possibly probably create factual hallucinations too if somebody shoves a transcript into the bot and asks it to drag data that it then mischaracterizes.
We simply noticed an Alabama federal courtroom lastly get robust on a hallucination case, kicking the Butler Snow lawyers off the case — over the objections of the shopper, no much less! — whereas heaping appreciable scorn on essentially the most senior attorneys who tried to keep away from duty by claiming that they’re too far above the mundane activity of checking another person’s work. Likewise on this case, the sanctions movement asserts that whereas the CHA threw Malaty below the CTA bus because the associate accountable for inserting the Mack case, the remainder of the senior Goldberg Segalla group bear duty for checking the filings too.
This case is now not a couple of single defective quotation that was the results of a “whoopsie” by a lawyer toying with new expertise. That is now a case about successively filed pleadings that have been essentially flawed based mostly on the truth that they relied on non-existent or misrepresented caselaw. It is a case that additionally includes patently false misrepresentations about what truly occurred at a trial of nice public significance. It is a case the place even within the face of inexcusable conduct, Goldberg Segalla and the CHA nonetheless press ahead with faulty pleadings in an try to throw out the jury’s verdicts.
As Choose Manasco wrote within the Butler Snow case of the AI hallucination sanctions to this point, “If fines and public embarrassment have been efficient deterrents, there wouldn’t be so many circumstances to quote.” This decide on this case would possibly quickly be part of Choose Manasco’s sentiment.
(Full sanctions movement on the subsequent web page…)
Earlier: Partner Who Wrote About AI Ethics, Fired For Citing Fake AI Cases
Court Kicks Lawyers Off Case After Finding Fake AI Cases In Filings
Joe Patrice is a senior editor at Above the Legislation and co-host of Thinking Like A Lawyer. Be happy to email any suggestions, questions, or feedback. Comply with him on Twitter or Bluesky in the event you’re serious about regulation, politics, and a wholesome dose of faculty sports activities information. Joe additionally serves as a Managing Director at RPN Executive Search.
