From Pauliah v. Univ. of Miss. Medical Center, decided last Tuesday by Judge Carlton Reeves (S.D. Miss.):
Courts across the country have dealt with the rising misuse of generative artificial intelligence to prepare court filings. Those cases have largely, if not entirely, dealt with citations to non-existent legal authority or the attribution of quotes to cases that do not contain the quoted material—produced as a result of what has come to be termed "AI hallucinations." This case is different [from other AI hallucination cases], as it appears that AI was used not to hallucinate the law, but to hallucinate the facts.
The declaration at issue contained multiple fabricated quotations, presented to the Court along with manufactured citations to deposition transcripts, as if they came from sworn testimony. The declaration also grossly mischaracterized testimony and other facts in the record. See Docket No. 141 at 4-6 (listing four outright fabricated quotations and other misrepresentations made to the Court). This declaration was filed in opposition to a motion for summary judgment. Counsel expressly used some of these fabricated "facts" to argue to the Court that this case contained genuine issues in factual dispute. Manufacturing "facts," then presenting them to the Court as genuine, threatens to corrupt the Court's analysis and undermine the integrity of the judicial process at the summary judgment stage.
