Hallucinated Summary
🚧 Under Construction
This entry is a placeholder. I am currently cataloguing both the fake citations that are shown in real cases and the citation graph of real AI hallucination cases. The canonical write-up is still in progress and is currently incomplete, with stub articles generated from the data in the Interactive Map of AI Hallucination Sanctions Cases. Please don't treat it as final or authoritative yet.
Definition
Why it matters
Worked examples
Cases with examples of this failure mode
- Novitzky v. TransUnion (C.D. Cal., 2024) — 1 instance
- In the Interest of R.A. (Iowa (State Court), 2025) — 1 instance
- Garner v. Kadince (Utah Court of Appeals, 2025) — 1 instance
- Vermont Supreme Court divorce appeal (AI quote) (Vermont Supreme Court, 2025) — 1 instance
- Wanyu Zhang v. National Public Radio, Inc. (D.D.C., 2025) — 8 instances
- United States v. Farris (6th Cir., 2026) — 4 instances
- [m]ere presence or knowledge of the offense is not sufficient to make a person a participant. (quoted to U.S.S.G. § 3B1.1 cmt. n.1)
- simply facilitating the offense without exercising decision-making authority is insufficient. (quoted to United States v. Washington, 715 F.3d at 985)
- [t]here was no evidence [the defendant] directed or supervised anyone else. (quoted to United States v. Anthony, 280 F.3d 694)
- The Sixth Circuit has reversed role enhancements on similar facts. (Washington upheld the enhancement)
- Payne v. The State (Supreme Court of Georgia, 2026) — 1 instance
- Williams v. State (Court of Appeals of Indiana, 2026) — 3 instances
- State v. Coleman (In re Norman) (Ohio Court of Appeals, Eleventh District, 2026) — 1 instance
- H.C. v. Contreras (California Court of Appeal, Fifth District, 2026) — 1 instance