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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Kohls v. Ellison
D. Minnesota · Jan 10, 2025
MN / federalEditorial impact: lowtrial
Direct answer
What happened in this matter?
Outcome: Expert Declaration Excluded. AI UseProfessor Jeff Hancock, a Stanford University expert on AI and misinformation, used GPT-4o to assist in drafting an expert declaration submitted by the Minnesota Attorney General's office in defense of a state law regulating AI deepfakes in elections.Hallucination DetailsThe declaration contained citations to three non-existent academic articles, apparently generated when the AI misinterpreted Hancock's notes to himself (e.g., "[cite]") as prompts to insert references.…
- Why the court cared
- The court found it "particularly troubling" that the expert exercised less care with a court filing than with academic work. While not faulting the use of AI itself, the court stressed the need for independent judgment and verification, stating the incident was a reminder that Rule 11's "inquiry reasonable under the circumstances" might now require attorneys to ask witnesses about their AI use and verification steps. The irony of an AI misinformation expert falling victim to AI hallucinations in a case about AI dangers was noted
- Why it matters now
- Ask every expert witness about AI use and verification; a struck declaration can sink the underlying case.
Why this matter is tracked
Outcome: Expert Declaration Excluded.
AI Use
Professor Jeff Hancock, a Stanford University expert on AI and misinformation, used GPT-4o to assist in drafting an expert declaration submitted by the Minnesota Attorney General's office in defense of a state law regulating AI deepfakes in elections.
Hallucination Details
The declaration contained citations to three non-existent academic articles, apparently generated when the AI misinterpreted Hancock's notes to himself (e.g., "[cite]") as prompts to insert references. Opposing counsel identified the fake citations.
Ruling/Sanction
Professor Hancock admitted the errors resulted from unchecked AI use, explaining it deviated from his usual practice of verifying citations for academic papers, and affirmed the substance of his opinions remained valid. Judge Laura M. Provinzino found the explanation plausible but ruled the errors "shattered his credibility". The court excluded the expert declaration as unreliable, emphasizing that signing a declaration under penalty of perjury requires diligence and that false statements, innocent or not, are unacceptable.
Key Judicial Reasoning
The court found it "particularly troubling" that the expert exercised less care with a court filing than with academic work. While not faulting the use of AI itself, the court stressed the need for independent judgment and verification, stating the incident was a reminder that Rule 11's "inquiry reasonable under the circumstances" might now require attorneys to ask witnesses about their AI use and verification steps. The irony of an AI misinformation expert falling victim to AI hallucinations in a case about AI dangers was noted.
Operational lesson
Ask every expert witness about AI use and verification; a struck declaration can sink the underlying case.
Record details
MinnesotaSingle-state evidence scope
CourtD. Minnesota
Jurisdictionfederal
Circuit8th Circuit
DateJan 10, 2025
GP
AI toolGPT-4o
Party typeExpert
OutcomeExpert Declaration Excluded
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
GPT-4o is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Expert Declaration Excluded
Correction behavior
Correction behavior is not separately verified in the current record.
Questions this record answers
- What happened in Kohls v. Ellison?
- Outcome: Expert Declaration Excluded. AI UseProfessor Jeff Hancock, a Stanford University expert on AI and misinformation, used GPT-4o to assist in drafting an expert declaration submitted by the Minnesota Attorney General's office in defense of a state law regulating AI deepfakes in elections.Hallucination DetailsThe declaration contained citations to three non-existent academic articles, apparently generated when the AI misinterpreted Hancock's notes to himself (e.g., "[cite]") as prompts to insert references.…
- Why does Kohls v. Ellison matter for legal AI risk?
- Ask every expert witness about AI use and verification; a struck declaration can sink the underlying case.
- What does the public record establish about Kohls v. Ellison?
- The record summarizes the outcome described in the linked public source. The recorded link is a secondary or other public source and should be checked against the docket where available. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Kohls v. Ellison summary?
- The recorded source is reason.com. It is classified as secondary or other linked source; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.