SerpApi.Org
A federal judge in Michigan rebuked the Trump administration’s Department of Justice after finding that a legal filing in an immigration detention case appeared to cite a nonexistent court decision, raising concerns that the citation was generated by artificial intelligence.
Department of Justice filing
Chief U.S. District Judge Hala Y. Jarbou of the Western District of Michigan addressed the issue in a July 16 order in a habeas corpus case brought by Immigration and Customs Enforcement detainee Izzeddin Ahmed Abdulgahffar Daghra. The detainee had challenged the government’s automatic stay of an immigration judge’s bond order.
Jarbou, who was appointed by President Donald Trump, ultimately dismissed the case as moot after the automatic stay expired and the government said Daghra could be released upon posting a $35,000 bond.
Although the underlying dispute was resolved, the judge devoted part of her three-page order to criticizing a Department of Justice filing that cited what she said is a nonexistent Sixth Circuit case, Taylor v. Hott. Government attorneys had argued that federal courts cannot “reweigh the evidence underlying a bond decision or second-guess the immigration judge’s discretionary judgment,” attributing the statement to the fabricated case.
‘Fake, hallucinated cases’
The incident comes as federal courts continue to scrutinize the use of artificial intelligence in legal filings, with judges increasingly warning attorneys about the risks of relying on AI-generated research without proper verification.
Jarbou said lawyers who use AI tools have a duty to carefully review their filings before submitting them to the court.
In a sharp warning, the judge wrote that AI-generated legal research has contributed to “a rash of cases” involving fabricated legal authorities, adding that courts are increasingly confronted with briefs containing “fake, hallucinated cases” that do not exist.
“It should be obvious that any attorney who uses AI must scrupulously review its work product to ensure that the cited cases exist and that the citations accurately and fairly represent the underlying case law,” the judge wrote.
DOJ receives a warning
Jarbou declined to impose sanctions but warned the Justice Department to ensure future filings do not include nonexistent legal authorities.
The case is the latest involving AI-related errors in court filings. In April, U.S. Magistrate Judge Robert T. Numbers II publicly reprimanded former federal prosecutor Rudy Renfer after he acknowledged using generative AI in a court brief that included false quotations, erroneous citations and mischaracterizations of case law.
