A federal judge has reprimanded Justice Department attorneys after discovering that a legal brief filed in an immigration detention case cited a court decision that does not exist and appeared to have been generated by artificial intelligence.
U.S. District Judge Hala Y. Jarbou, a Trump appointee serving in the Western District of Michigan, addressed the issue while dismissing a lawsuit brought by an ICE detainee whose request for relief had become moot. Before closing the case, however, she singled out the Justice Department’s filing for relying on a fabricated legal citation.
Judge says attorneys must verify AI-generated work
In her order, Jarbou said the nonexistent citation “was likely produced by generative artificial intelligence” and reminded attorneys that using AI does not relieve them of their professional responsibilities.
“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.
The fabricated citation purported to reference a Sixth Circuit Court of Appeals decision supporting the government’s legal position. The judge found that no such case exists.
Filing came in ICE detention case
The error appeared in a Justice Department filing defending the government’s position in an Immigration and Customs Enforcement detention case. By the time the judge ruled, the dispute itself had become moot because the detainee’s automatic stay had expired.
Although Jarbou did not impose sanctions, she used the opinion to emphasize that lawyers — not AI software — bear ultimate responsibility for every factual assertion and legal citation submitted to a federal court.
Latest example of AI “hallucinations” in court
The incident is the latest in a growing number of cases involving AI “hallucinations,” in which generative AI systems fabricate cases, quotations or other legal authorities that appear authentic but do not exist.
Federal judges around the country have increasingly warned attorneys that while AI can assist with research and drafting, every citation must be independently verified before a filing is submitted. Some lawyers have faced sanctions or other disciplinary action after submitting briefs containing fabricated precedents.
Jarbou ultimately dismissed the underlying immigration case but left little doubt that she expects greater care from government attorneys going forward, warning that reliance on unverified AI-generated material has no place in federal court.
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