Ninth Circuit on AI Hallucinations
The Ninth Circuit has issued a disciplinary order regarding the use of generative AI in legal filings. The court highlighted issues of AI hallucinations, including fabrications and inaccuracies, which can lead to significant errors in legal documents. Attorneys must exercise diligence and ensure that all citations are accurate and relevant, regardless of whether they are generated by AI or not.
- ▪The Ninth Circuit found that attorneys filed briefs containing nonexistent cases and misattributed quotations due to reliance on generative AI.
- ▪The court emphasized the importance of identifying both fabrications and inaccuracies in AI-generated content.
- ▪Legal-specific AI tools have shown high rates of hallucinations, with Westlaw and Lexis reporting 17% and 33% inaccuracies, respectively.
Opening excerpt (first ~120 words) tap to expand
AI in Court Ninth Circuit on AI Hallucinations Eugene Volokh | 6.3.2026 2:36 PM Some excerpts from today's long opinion in LNU v. Blanche, decided by the Ninth Circuit by Judge Richard Paez, Carlos Bea, and Danielle Forrest: Attorneys Mike Singh Sethi and William Rounds filed briefs in this Court with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases. Sethi and Rounds claimed that the errors were the product of innocent typographical mistakes. And they repeatedly denied the possibility that generative artificial intelligence ("AI") might have produced the errors.
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Excerpt limited to ~120 words for fair-use compliance. The full article is at Reason Magazine.
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