2 posts tagged with "Google"

In re: Turner, Disbarred Attorney and Fake Cases​

Iowa Supreme Court Attorney Disciplinary Board v. Royce D. Turner (Iowa)​

In July 2025, the Iowa Supreme Court Attorney Disciplinary Board moved to strike multiple recent filings by Respondent Royce D. Turner, including Brief in Support of Application for Reinstatement, because they contained references to a non-existent Iowa case. [Source 1(https://www.abajournal.com/files/Iowa_Supreme_Court_v.Royce_D_Turner_motion_to_strike.pdf)

Several of Respondent’s filings contain what appears to be at least one AI-generated citation to a case that does not exist or does not stand for the proposition asserted in the filings. —In re: Turner

The Board left room with “or does not stand for the proposition,” but it appears that this was straightforwardly a hallucinated fake case cited as “In re Mears, 979 N.W.2d 122 (Iowa 2022).”

Watch out for Doppelgänger hallucinations!​

I searched for the fake case title “In re Mears, 979 N.W.2d 122 (Iowa 2022)” cited by Turner to see what Google results came up. What I found was Google hallucinations seeming to “prove” that the AI-generated case title from Turner referred to a real case. Therefore, simply Googling a case title is not sufficient to cross-reference cases, because Google’s AI Overview can also hallucinate. As I have frequently mentioned, it is important for law firms that claim not to use AI to understand that many common and specialist programs now include generative AI that can introduce hallucinations, such as Google, Microsoft Word, Westlaw, and LexisNexis.

First Google Hallucination​

The first time, Google’s AI Overview hallucinated an answer stating that the case was a real Iowa Supreme Court decision about court-appoint attorney’s fees to a lawyer, but the footnotes linked by Google were actual to Mears v. State Public Defenders Office (2013). Key Takeaway: Just because an LLM puts a footnote next to its claim does not mean the footnote supports the statement.

Second Google Hallucination​

I searched for the same case name again later, to see if Google would warn me that the case did not exist. Instead, it created a different hallucinated summary.

The summary and links related to a 2022 Iowa Supreme Court case, Garrison v. New Fashion Pork LLP, No. 21–0652 (Iowa 2022). Key Takeaway: LLMs are not deterministic and may create different outputs even when given the same inputs.

Perplexity AI’s Comet Browser​

Perplexity AI, an AI search engine company, recently released a browser for macOS and Windows to compete with browsers like Chrome, Safari, and Edge. I get a lot of ads for AI stuff on social media, so I’ve been bombarded with a lot of different content recently promoting Comet. To be frank, most of it is incredibly tasteless to the point that I think parents and educators should reject this product on principle. They are clearly advertising this product to students (including medical students!) telling them Comet will help them cheat on homework. There isn’t even the fig leaf of “AI tutoring” or any educational value.

Comet Browser’s Hallucination​

I searched for the fake case title “In re Mears, 979 N.W.2d 122 (Iowa 2022)” cited by Turner in a new installation of Comet. It is important to note that people can “game” these types of searches by conducting searches over and over until the AI makes one mistake, then screenshot that mistake to make a point. That is not what I’m doing here. This was the very first result from my first search. It was a hallucination that explicitly stated the fake case “is a 2022 Iowa Supreme Court decision” although this is followed by caveats that cast doubt on whether it really is an existing case:

"In re Mears, 979 N.W.2d 122 (lowa 2022)" is a 2022 lowa Supreme Court decision, but the currently available sources do not provide a readily accessible summary, holding, or specific details about the case itself. It appears this citation may pertain to legal doctrines such as cy près or charitable trust law, as suggested by the limited context in search returns, but direct case facts, parties, and the detailed ruling were not found in available summaries or law review discussions. georgialawreview If you need more detailed information, legal databases such as Westlaw, LexisNexis, or the official lowa Supreme Court opinions archive would provide the official opinion, including the background, holding, and legal reasoning of "In re Mears, 979 N.W.2d 122 (lowa 2022)".

If you were to follow up on the caveats in the second paragraph, you would learn that the case does not exist. However, this is still a hallucination, because it is describing the case as it if exists and does not mention the one relevant source, In re: Turner, which would tell you that it is a citation to a fake case.

If you are a small business owner who wants nothing to do with AI, I appreciate that decision. Midwest Frontier AI Consulting supports business owners who want to use AI responsibly and business owners who want to make an informed decision not to use AI. However, you still need to learn about generative AI, even if only to avoid it and mitigate the negative effects.

Your customers are using AI to learn about your business, often without even realizing they are using AI. “Google” has been a verb for over two decades now according to Wikipedia, but “googling something,” hasn’t stayed the same. AI tools have moved into familiar areas like Google Search and Google Maps. Here are three ways your customers may be using generative AI to learn about your business from Google’s AI tools, and what you can do about it.

AI Overviews in Google Search​

Google’s Gemini AI attempts to summarize website information and provide an overview. However, the AI summary can introduce errors ("hallucinations") that mislead customers. For example, a local Missouri pizzeria was inundated with customer complaints about “updated [sic, appears they meant to say ‘outdated’] or false information about our daily specials” described by Google’s AI Overview (Pizzeria’s Facebook Post).

What Not to Do​

Don’t call the information “fake” if it is really information taken out of context. For example, the pizzeria’s Facebook page shows they offer a deal for a large pizza for the price of a small pizza, but only on Wednesdays (outdated information). It is still legitimate to criticize the AI and it is still legitimate to tell customers who want the deal on another day of the week that the offer is only valid on Wednesdays. However, claiming the offer is “made up by the AI” will probably not calm down a customer who may then go to the business’s Facebook profile and see several posts about similar deals (but only on Wednesdays).

Don’t simply tell customers “Please don’t use Google AI.” The customers probably do not realize they are using AI at all. The AI Overview appears at the top of Google Search. Most people probably think they are “just googling it” like they always have and don’t realize the AI features have been added in. So warning them not to use something they didn’t opt into and aren’t actively aware of using is not going to help the situation.

What To Do​

• AI-focused solutions. If AI is going to mix things up like this, you can try to: ** Delete old posts about deals that are not active or make temporary posts, so that AI hopefully won’t include the information in summaries later. ** Word posts carefully with AI in mind. Maybe “only on Wednesday” would be better than “EVERY Wednesday.” Spell out something that would be obvious to a human but not necessarily an AI, like “not valid on any other day of the week.”
• Customer-focused solutions. Ultimately, it is hard to predict how the AI will act, though, so you will need to prepare for potentially angry customers: ** Train staff on how to handle AI-created customer confusion (or think about how you yourself will talk to customers about it). ** Post signs regarding specials and preempt some AI-created confusion.