Don’t do this.

I know a lot of you are tired of reminders to not rely on AI because it hallucinates, but attorneys--yes barred, licensed lawyers--continue to not just do this but some continue to DOUBLE DOWN* on it when called out (by opposing litigants AND by courts).

*Beware, more all caps forthcoming, because I cannot fathom trying to pull off what this plaintiff attempted here.

Take the case of Reaves Law Firm v. Baker Donelson, Case No. 25-CV-2623 (W.D. Tenn.).

That Court's June 2nd order calls out this exact misconduct:

Plaintiff (a law firm) filed papers to which defendant (also a law firm) called out plaintiff for misusing AI, citing a HOST of hallucinated references and made up assertions.

After defendant called plaintiff out, plaintiff filed MORE papers with MORE hallucinations.

The Court reviewed everything and issued a show cause order with EXPLICIT instructions to plaintiff, including:

→ identify all cases defendant calls suspicion to,
→ confirm whether these cases exist and if they exist identify how that was confirmed,
→ confirm whether the cases stand for the propositions plaintiff claims, and if any quoted language is not in these cases explain where (or in what cases) the language comes from,
→ if a case or quote or proposition doesn't exist explain what plaintiff did (if anything) to verify these items before filing the questioned papers with this court, and
→ tell the Court what if any other cases in this federal district plaintiff has filed papers with hallucinations.

From there, and I quote, "Plaintiff's counsel failed to follow these instructions" and for several hallucinations plaintiff "took none of the steps the Court required it to take."

It gets worse: Plaintiff never "acknowledge[d] that AI had any role in the drafting of the filings at issue."

There's more: Plaintiff "purports to accept full and complete responsibility . . . [but] throughout its response, [plaintiff] simultaneously minimizes the issues for which it is accepting responsibility, and appears to cast blame elsewhere."

BUT WAIT: Plaintiff further "characterizes the issues Defendants and the Court identified as PURELY CLERICAL, limited to FORMATTING and INADVERTENT CITATION INCLUSIONS."

This is a real case with real attorneys--from THIS MONTH, in the year of our lord 2026.

Not shockingly, the Court, relying on Rule 11, sanctioned plaintiff, ordering it to pay defendants' attorneys' fees and requiring the clerk to forward this order to all other judges in the Western District of Tennessee and to Tennessee's lawyer disciplinary entity.

If attorneys are behaving this way when it comes to AI, with hallucination issues that have been well identified and sanctioned for a year or more at this point, imagine what lay people--pro se litigants, students, children--are facing, creating, attempting.

AI education, training, governance, and more is crucial. I worry not enough of us are getting it or paying attention.

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