Twenty-Four Cases That Don't Exist
- Admitted
- 2026-05-15
- Source dataset
- Other / sample
- Failure mode
- Hallucination with side effects
- Agent system
- Single agent
- Tool access
- Read-only
- Industry
- Legal
Presenting Behaviour
In an appeal before the Sixth Circuit, briefs filed on behalf of the appellants cited more than two dozen court cases that do not exist, along with quoted language that didn't appear in the real cases they were attached to and citations that failed to support the legal points they were supposed to back up. When the court issued an order asking the filing attorneys to explain whether generative AI had been used, they did not meaningfully respond. The court removed one attorney from the case, denied him compensation for his work on the appeal, and imposed the stiffest available penalty under the applicable procedural rule, along with $15,000 in punitive sanctions per attorney and reimbursement of the other side's legal fees.
Case Replay
A reconstruction, not a simulation. This sequence is reconstructed from the public incident record and summarised in our own words. It is a static record of what was reported, and nothing here can be run or replayed live.
4 steps
- Briefs drafted. Appellants' briefs are prepared for an appeal.
- Fake citations filed. More than two dozen cited cases do not exist. This is where the agent derailed.
- Court asks. The court asks whether generative AI was used; no meaningful reply.
- Sanctions. One attorney is removed, and punitive sanctions and fees are imposed.
Differential Diagnosis
Delusional Disorder (a fixed, sustained false belief maintained across a long task), considered, but doesn't fit the shape of the error: this wasn't one mistaken premise pursued consistently, it was two dozen separate, unrelated fabrications scattered across the filings.
Malingering (a shortcut manufactured to satisfy a goal), closer, since producing a citation-heavy brief quickly is an obvious incentive, but there's no indication the underlying legal arguments were otherwise sound and just dressed up with fake support; the fabrication ran through the substance of the work itself.
Brief Psychotic Disorder, most consistent with the pattern. Each fabricated citation was a confident, specific, checkable claim stated as fact and not actually true, produced in isolation rather than as part of one sustained false belief, exactly the profile of a short break from accuracy under pressure with no larger pattern of dysfunction.
Working Diagnosis
Brief Psychotic Disorder: the filings contained numerous, discrete, high-confidence factual claims (case citations) that were fabricated outright, each independently wrong rather than downstream of one sustained misunderstanding.
Discussion
A model that fabricates a citation and a model that correctly retrieves one look identical on the page (both are stated with the same confident tone) which is exactly why this keeps happening across courts. The safeguard isn't a smarter model, it's a boring, mandatory one: every citation in a filing gets checked against a real database before it goes out the door, by a person or a tool built for that one job.
Mitigation Strategy
Check every citation against a real legal database before filing.
Governance Guardrails
Mandatory citation verification; disclosure rules for generative AI use; filer accountability.
Typical Presentation in Human Patients
General clinical background, included for context. Not medical advice, and not a diagnosis of any individual.
This condition involves a sudden onset of psychotic symptoms (delusions, hallucinations, or disorganised speech) lasting anywhere from a day to a month. It's frequently triggered by a significant stressor, and the person typically returns fully to their prior level of functioning once the episode resolves.
Source Note
Sixth Circuit Appellate Blog
https://www.sixthcircuitappellateblog.com/recent-cases/sixth-circuit-sanctions-attorneys-for-fake-citations-what-does-this-mean-for-use-of-ai/