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Court Slams Lawyer for AI Hallucinations in Briefs
11 Jul
Summary
- A court rebuked a lawyer for submitting AI-generated briefs with fake case citations.
- The court warned against carelessly outsourcing legal work to artificial intelligence.
- The lawyer apologized for 'erroneous or unverifiable' case citations from research oversights.

A U.S. appeals court has issued a stern rebuke to a Florida lawyer and county official for submitting legal briefs filled with "fake and hallucinated" material produced by artificial intelligence. The Atlanta-based 11th U.S. Circuit Court of Appeals flagged attorney Anthony Sabatini for including non-existent case citations in briefs for a commercial aviation employment dispute. The court stated that outsourcing legal work to AI violated the lawyer's ethical duties and stressed that AI is "no substitute for actual intelligence."
Sabatini, who also serves as a Lake County commissioner, had previously apologized to the court last year for including "erroneous or unverifiable" case citations, citing "research oversights." The court panel affirmed that lawyers bear the responsibility to verify AI-generated work. Consequently, Sabatini will be referred to the court's Committee on Lawyer Qualifications and Conduct. This incident highlights a growing concern in the legal field regarding the responsible use of generative AI tools.