US lawyers fined after submitting citations generated by ChatGPT

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A US judge has fined two lawyers for submitting fake citations generated by ChatGPT in a court filing.  

The two lawyers, and their law firm Levidow, Levidow & Oberman, were fined $5,000 for presenting fictitious legal citations generated by AI to make their argument in an aviation injury claim.  

Levidow, Levidow & Oberman said that its lawyers disagreed with the court’s allegations that they had acted in bad faith. “We made a good-faith mistake in failing to believe that a piece of technology could be making up cases out of whole cloth.” 

Steven Schwartz, one of the two lawyers from Levidow, Levidow & Oberman, admitted to using ChatGPT, which invented six cases that Schwartz then cited in a legal brief during a case against Colombian airline Avianca. 

Judge P Kevin Castel argued that it wasn’t the use of ChatGPT that was “inherently improper”, but the fact that the lawyers and their firm had “abandoned their responsibilities when they submitted non-existent judicial opinions with fake quotes and citations”. Castel reasoned the fine was enacted because the lawyers “then continued to stand by the fake opinions after judicial orders called their existence into question”. 

The citations Schwartz used, provided by ChatGPT, included errors such as: 

• citing cases that weren’t real; 
• misidentifying judges; or 
• referencing the involvement of airlines that don’t exist. 

Castel remarked that although the AI chatbot did offer “some traits that are superficially consistent with actual judicial decisions”, other portions were “gibberish” and “nonsensical”.