Preparing the requested public record.
Preparing the requested public record.
D. New Mexico · Apr 2, 2025
Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. Outcome: Monetary sanction; required CLE on legal ethics and AI; mandatory self-reporting to NM and TX state bars; report of subcontractor to NY state bar; required notification to LAWCLERK.
Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. Outcome: Monetary sanction; required CLE on legal ethics and AI; mandatory self-reporting to NM and TX state bars; report of subcontractor to NY state bar; required notification to LAWCLERK.
Counsel hired a freelance attorney through LAWCLERK to prepare a filing. He made minimal edits and admitted not verifying any of the case law before signing. The filing included multiple fabricated cases and misquoted others. The court concluded these were AI hallucinations, likely produced by ChatGPT or similar.
Examples of non-existent cases cited include:Moncada v. Ruiz, Vega-Mendoza v. Homeland Security, Morales v. ICE Field Office Director, Meza v. United States Attorney General, Hernandez v. Sessions, and Ramirez v. DHS.All were either entirely fictitious or misquoted real decisions.
The Court sanctioned Counsel by:Ordering a $1,500 fineRequiring a 1-hour CLE on AI/legal ethicsOrdering him to self-report to the New Mexico and Texas barsOrdering him to report the freelance lawyer to the New York barRequiring notification of LAWCLERKRequiring proof of compliance by May 15, 2025
The court emphasized that counsel’s failure to verify cited cases, coupled with blind reliance on subcontracted work, constituted a violation of Rule 11(b)(2). The court analogized to other AI-sanctions cases. While the fine was modest, the court imposed significant procedural obligations to ensure deterrence.
Outsourced drafting is still your signature; verify every cite from freelance work before filing or face dual-state bar referrals.
The current record does not establish a specific AI tool. Do not infer AI use beyond the source.
Monetary sanction; required CLE on legal ethics and AI; mandatory self-reporting to NM and TX state bars; report of subcontractor to NY state bar; required notification to LAWCLERK
Correction behavior is not separately verified in the current record.
7 citation, quotation, or authority issues are recorded in the source dataset.
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.