Lawyers’ Bar Journal Article Discussing Their AI-Hallucination Errors Doesn’t Entirely Satisfy Judge, but ...
Summary
In Doe v. University of North Carolina System, Chief Judge Martin Reidlinger ordered plaintiff's counsel to explain why they should not be sanctioned after multiple filing errors, including nonexistent cases, fabricated quotations, misstated holdings, irrelevant authorities, and missing pinpoint or court information. Counsel admitted the problems stemmed largely from AI misuse or misunderstanding and failure to verify outputs despite certifications, and they agreed to publish a state bar journal article warning other lawyers.
The article, by Fred W. DeVore III and Rob Wilder, publicly acknowledged serious mistakes, but the judge said it minimized their impact and contained misleading statements, including the claim that cases were correct while quotes were hallucinated and that a certification about not using AI was technically true. The judge criticized the article for not fully describing the harm or appreciating Rule 11 and standing-order verification duties. Still, because the lawyers had a history of exemplary conduct, acted in good faith, and showed contrition through public admissions, the court found the article sufficient to discharge the show-cause order without sanctions.
(Source:Reason Magazine)