Lawyer's use of 'fake and hallucinated' citations gets reprimand from US appeals court

A Florida lawyer and county official were reprimanded for filing briefs that included “fake and hallucinated” artificial intelligence-generated information. Getty Images)
The 11th U.S. Circuit Court of Appeals reprimanded a Florida lawyer and county official for filing briefs that included “fake and hallucinated” artificial intelligence-generated information Friday, issuing a broad message about outsourcing legal work to an AI.
The order by the Atlanta-based 11th Circuit said Anthony Sabatini, serving as the plaintiffs’ counsel in an employment case against Atlas Air, produced multiple briefs containing nonexistent citations, according to Reuters.com. Sabatini, a former member of the Florida House of Representatives, apologized to the court last year for submitting filings containing erroneous or unverifiable case citations. While lawyers are not barred from using AI, it is understood the technology can fabricate case citations and misquote the law.
“By outsourcing his legal work to an AI algorithm, Sabatini violated his ethical duties to both his clients and this court,” a three-judge panel wrote. “Whatever the merits of artificial intelligence, it is no substitute for actual intelligence.” The 11th Circuit will refer Sabatini to the court’s Committee on Lawyer Qualifications and Conduct.
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