The evidence behind ChatGPT’s Fake Cases Went to Court

The documents behind the article, with excerpts linked back to their place in the story. Open a record, inspect the claim’s check, or report an error.

AI gone wrong63 distinct sourced claims · 16 documents · Source checks: 2026-10-14 · Article facts as of 2026-10-16 · Reports checked: 0. Corrections: 0.

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  1. The actual chat

    The phone screenshots filed with the court.

  2. The court’s account

    The findings and sanctions ruling.

The groups describe source types, not a guarantee that everything in a document is true. A check describes the underlying claim; read its qualifiers in the excerpt.

Source type

Public records and guidance

7 documents

Court and legislative records, regulator material and official guidance. A filed allegation or testimony remains distinct from a finding.

S01

Mata v. Avianca, 678 F.Supp.3d 443 (S.D.N.Y. 2023), Opinion and Order on Sanctions

In the article 83 excerpts

  1. Article

    The case name was Varghese v. China Southern Airlines Co., Ltd.

    C67 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01

  2. Article

    Its citation supplied a volume, a page, a court and a year: 925 F.3d 1339, Eleventh Circuit, 2019.

    C67 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01

  3. Article

    Peter LoDuca put it before a federal court in New York on March 1, 2023, in a filing researched and written by his colleague Steven A. Schwartz.

    C03 C06 C67 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01

  4. Article

    The address exists; the case named on the filing does not.

    C11 C26 C67 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01 · S20

  5. Article

    Judge P. Kevin Castel would find that ChatGPT had fabricated the authorities Schwartz supplied.

    C11 C32 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01

Show all 83 article excerpts
  1. Article

    The submitted citation and the reporter record identify different decisions.

    C06 C67 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · Figure · Supporting sources: S01 · S20

  2. Article

    Varghese v. China Southern Airlines Co., Ltd., 925 F.3d 1339 (11th Cir. 2019), appeared in the document filed on March 1, 2023.

    C06 C67 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · The reference and the record · In the filing · Supporting sources: S01

  3. Article

    The publication reference leads to a different decision; the court found that ChatGPT had fabricated Varghese.

    C11 C48 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Figure note · Supporting sources: S01 · S20

  4. Article

    A citation is a set of directions to a source. Writing plausible directions and locating what they name are different tasks. Here, the reference reached a real page without reaching the promised decision.

    C67 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01 · S20

  5. Article

    The client was Roberto Mata, who said a serving cart injured his knee during an overnight Avianca flight from El Salvador to New York in August 2019.

    C01 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01 · S02

  6. Article

    He refiled his lawsuit in February 2022, and Avianca moved it into federal court.

    C01 C03 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  7. Article

    The airline then asked for dismissal: the Montreal Convention, the treaty governing the claim, allowed two years to sue.

    C05 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01 · S02

  8. Article

    Schwartz’s first instruction to ChatGPT asked it to argue for that pause; subsequent requests asked for cases and particular holdings.

    C17 C18 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  9. Article

    Schwartz did the legal work, but he could not practise in this federal court, so LoDuca appeared as the lawyer responsible for the case there.

    C04 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  10. Article

    By Schwartz’s account, his firm’s Fastcase research account offered limited access to federal decisions when he began this research, and the firm had no Westlaw or LexisNexis subscription.

    C15 Verified, reworded before publishing Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  11. Article

    He had never used ChatGPT before, he said, and had heard about it through news coverage and his family.

    C16 Verified, reworded before publishing Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  12. Article

    At the later hearing, he described his mistaken picture of the tool as “like a super search engine”.

    C14 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  13. Article

    Castel’s account of what happened when Schwartz requested more authorities was shorter: “the chatbot complied by making them up.”

    C18 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01

  14. Article

    Avianca’s lawyers went looking for the authorities.

    C08 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  15. Article

    Their March 15 reply, signed by Bartholomew J. Banino, reported that they were “unable to locate most of the case law cited”.

    C08 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S06

  16. Article

    Mata’s side did not withdraw the document or explain the missing cases, and the court’s own search also failed to locate several of them.

    C10 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  17. Article

    Castel asked to see the decisions themselves, warning that failure to supply them would mean dismissal.

    C19 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  18. Article

    LoDuca sought more time, saying he was on vacation—a statement Castel later found knowingly false.

    C20 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  19. Article

    What eventually arrived was an affidavit with supposed decision excerpts, drafted and assembled by Schwartz.

    C21 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  20. Article

    The reply, the court’s orders and the later submission are dated events; the undated chatbot exchanges are separate.

    C08 C19 C21 C29 Verified Report an error in this excerpt

    The missing decisions acquire more text · Figure · Supporting sources: S01

  21. Article

    On March 15, 2023, Avianca’s lawyers reported that they could not locate most of the cited case law.

    C08 Verified Report an error in this excerpt

    The missing decisions acquire more text · The requests for the decisions · The reply · Supporting sources: S01

  22. Article

    On April 11 and 12, 2023, the court ordered copies of the decisions, warning that failure to comply would mean dismissal.

    C19 Verified Report an error in this excerpt

    The missing decisions acquire more text · The requests for the decisions · The orders · Supporting sources: S01

  23. Article

    On April 25, 2023, LoDuca filed an affidavit with purported decision excerpts that Schwartz had prepared.

    C21 Verified Report an error in this excerpt

    The missing decisions acquire more text · The requests for the decisions · The submission · Supporting sources: S01

  24. Article

    The date of Schwartz’s chatbot questions was not established, so those exchanges are not placed on this timeline.

    C29 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Figure note · Supporting sources: S01

  25. Article

    The added writing brought its own clues. The purported Petersen v. Iran Air decision cited itself as an earlier authority.

    C25 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  26. Article

    Castel called the supposed Varghese opinion’s legal analysis “gibberish”.

    C23 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  27. Article

    Even its court docket number, the identifier assigned to a proceeding, belonged to a different case.

    C48 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S20

  28. Article

    On May 4, Castel ordered LoDuca to explain why citing nonexistent decisions should not lead to a court penalty.

    C27 Verified Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01

  29. Article

    The record was about to gain a different kind of exhibit: the questions Schwartz had asked on his phone.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S17

  30. Article

    Schwartz’s May 25 filing attached smartphone screenshots and brought the first acknowledgment from the lawyers or their firm that ChatGPT had generated the bogus authorities.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  31. Article

    That is the filing date, not an established date for the conversation: Schwartz’s accounts differed, and the court called them “shifting and contradictory explanations”.

    C29 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01

  32. Article

    In the screenshots, Schwartz asked: “Is varghese a real case”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  33. Article

    ChatGPT replied that it “is a real case”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  34. Article

    He asked: “Are the other cases you provided fake”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  35. Article

    “No, the other cases I provided are real and can be found in reputable legal databases such as LexisNexis and Westlaw.”

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  36. Article

    A reply preserved in Schwartz’s May 25 filing asserted that ChatGPT had double-checked the invented decision.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Figure · Supporting sources: S01 · S17

  37. Article

    The conversation’s date was not established.

    C29 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Figure · Supporting sources: S01

  38. Article

    The chatbot’s double-check produced another assurance, not a court decision.

    C26 C11 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S17 · S01

  39. Article

    It also directed him to the services his firm did not subscribe to, according to his testimony.

    C28 C15 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  40. Article

    The lawyers ultimately acknowledged six invented decisions; the Eleventh Circuit’s clerk separately confirmed that Varghese was not an authentic ruling of that court.

    C22 C26 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01

  41. Article

    A citation has a recurring form; the decision it names still needs an independent existence check. The Varghese reference shows why: its publication details looked usable while pointing into somebody else’s case.

    C67 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S20

  42. Article

    At the June 8 hearing, Schwartz testified that he had entered the Varghese citation but could not locate the decision.

    C13 Verified, reworded before publishing Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  43. Article

    He described imagining an unpublished opinion, an appeal or a difficulty getting access.

    C12 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  44. Article

    “I just never thought it could be made up.”

    C12 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  45. Article

    The court could not settle whether that failed lookup came before the March filing or the April affidavit.

    C13 Verified, reworded before publishing Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  46. Article

    Either way, Castel found, Schwartz knew before a submission that the complete text could not be found and did not disclose it.

    C13 Verified, reworded before publishing Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  47. Article

    The earlier preparation and review are clearer. Schwartz wrote from the chatbot’s excerpts without possessing a complete copy of any of its generated decisions.

    C46 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  48. Article

    LoDuca testified that he had been “looking for a flow”; he checked the writing without reviewing any of the authorities it cited.

    C07 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  49. Article

    The court recorded his reliance on a colleague of more than twenty-five years whose work he believed would be reliable.

    C40 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  50. Article

    The preparation and review did not include reading the complete decisions cited from ChatGPT.

    C46 C07 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Figure · Supporting sources: S01

  51. Article

    Schwartz built the March filing from ChatGPT’s excerpts without having any complete generated decision.

    C46 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · From research to signature · Preparation · Supporting sources: S01

  52. Article

    LoDuca reviewed the writing for style without reviewing any of the cited authorities.

    C07 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · From research to signature · Review · Supporting sources: S01

  53. Article

    LoDuca filed the document on March 1, 2023.

    C06 Verified, reworded before publishing Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · From research to signature · Certification · Supporting sources: S01

  54. Article

    His signature certified a reasonable inquiry into the basis of its legal arguments.

    C77 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · From research to signature · Certification · Supporting sources: S01

  55. Article

    Schwartz’s separate unsuccessful lookup cannot be securely placed before the March brief rather than the April affidavit.

    C13 Verified, reworded before publishing Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Figure note · Supporting sources: S01

  56. Article

    That answers what the lawyers checked before the citations reached the judge: the language had been reviewed, but the decisions behind it had not.

    C46 C07 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  57. Article

    In this account’s reading of the record, the review before signing was a chance to require those decisions, rather than accept the excerpts alone.

    C46 C07 C77 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  58. Article

    The signature carried a duty of its own. Castel quoted Rule 11: the signer certifies a reasonable inquiry into legal positions, supported by current law or a serious proposal for changing it.

    C77 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  59. Article

    Having a colleague prepare the document did not remove that responsibility.

    C04 C77 Verified Report an error in this excerpt

    One lawyer supplied excerpts; another reviewed the writing · Supporting sources: S01

  60. Article

    Both lawyers testified under oath and expressed remorse at the June hearing.

    C31 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  61. Article

    On June 22, 2023, Castel found bad faith through “conscious avoidance and false and misleading statements to the Court”.

    C32 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  62. Article

    His explanation of conscious avoidance required awareness of a high probability that something was true and a deliberate refusal to confirm it; a foolish mistake alone was insufficient.

    C68 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  63. Article

    A shared financial penalty applied to the lawyers and their firm.

    C33 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  64. Article

    The lawyers also had to write to their client and the judges falsely named as authors.

    C34 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  65. Article

    On June 22, 2023, the court imposed sanctions for the lawyers’ conduct and separately dismissed Mata’s claim as late.

    C32 C33 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Figure · Supporting sources: S01 · S02

  66. Article

    On June 22, 2023, Schwartz, LoDuca and their firm received one $5,000 penalty.

    C32 C33 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Separate grounds, separate consequences · The lawyers’ conduct · Supporting sources: S01

  67. Article

    Each could be held liable for the entire shared amount; the lawyers also had to write to their client and the judges falsely credited as opinion authors.

    C33 C34 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Separate grounds, separate consequences · The lawyers’ conduct · Supporting sources: S01

  68. Article

    Castel also recognized a legitimate use for reliable AI assistance while maintaining lawyers’ obligation to ensure accurate filings.

    C35 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  69. Article

    His account of the broader harms included wasted court and opposing-party resources, and the possibility that a client would lose arguments grounded in authentic decisions.

    C49 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S01

  70. Article

    The opening citation can be checked against the publication record and the court’s recorded confirmation.

    C67 C22 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Figure · Supporting sources: S01 · S20

  71. Article

    The filing named Varghese v. China Southern Airlines Co., Ltd. at 925 F.3d 1339.

    C67 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Check the reference against the record · Identify the source · Supporting sources: S01

  72. Article

    The court recorded the Eleventh Circuit clerk’s confirmation that Varghese was not an authentic ruling of that court.

    C22 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Check the reference against the record · Resolve the mismatch · Supporting sources: S01

  73. Article

    Schwartz testified that he had been unable to find Varghese.

    C13 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Figure note · Supporting sources: S01

  74. Article

    The ruling leaves open whether that lookup came before the March filing or the April affidavit.

    C13 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Figure note · Supporting sources: S01

  75. Article

    An unsuccessful search was already part of Schwartz’s account, as were the explanations he offered himself for it.

    C13 C12 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01

  76. Article

    Asking the chatbot for reassurance supplied no missing opinion.

    C28 C22 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S17

  77. Article

    Avianca’s lawyers instead reported the authorities they could not locate.

    C08 Verified Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S06

  78. Article

    You can inspect the mismatch that began this story. The name attached to the reference was Varghese; the decision at volume 925, page 1339 is J.D. v. Azar.

    C67 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S20

S02

Mata v. Avianca, ECF 55, Opinion and Order granting motion to dismiss

In the article 9 excerpts

  1. Article

    The client was Roberto Mata, who said a serving cart injured his knee during an overnight Avianca flight from El Salvador to New York in August 2019.

    C02 Verified, reworded before publishing Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01 · S02

  2. Article

    The airline then asked for dismissal: the Montreal Convention, the treaty governing the claim, allowed two years to sue.

    C36 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S01 · S02

  3. Article

    Mata’s side argued that the clock had paused during Avianca’s bankruptcy, begun in May 2020, while lawsuits against the airline were on hold.

    C86 Verified Report an error in this excerpt

    Schwartz needs an answer to a deadline · Supporting sources: S02

  4. Article

    Mata’s case was decided separately: Castel rejected the argument that bankruptcy had paused the treaty’s deadline.

    C36 C86 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S02

  5. Article

    On June 22, 2023, the court imposed sanctions for the lawyers’ conduct and separately dismissed Mata’s claim as late.

    C36 C86 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Figure · Supporting sources: S01 · S02

Show all 9 article excerpts
  1. Article

    In a separate June 22, 2023 ruling, Mata’s claim was dismissed for exceeding the Montreal Convention’s two-year deadline.

    C36 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Separate grounds, separate consequences · The client’s claim · Supporting sources: S02

  2. Article

    The court held that bankruptcy had not paused that period.

    C86 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Separate grounds, separate consequences · The client’s claim · Supporting sources: S02

  3. Article

    The claim was dismissed on timeliness grounds, not because the citations were invented.

    C36 C86 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Figure note · Supporting sources: S02

  4. Article

    The dismissal rested on the filing deadline, not the invented decisions.

    C36 C86 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S02

S06

Mata v. Avianca, ECF 24, Avianca reply memorandum (Mar 15, 2023)

In the article 2 excerpts

  1. Article

    Their March 15 reply, signed by Bartholomew J. Banino, reported that they were “unable to locate most of the case law cited”.

    C42 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S06

  2. Article

    Avianca’s lawyers instead reported the authorities they could not locate.

    C42 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S06

S07

Mata v. Avianca docket (CourtListener API v4)

In the article 1 excerpt

  1. Article

    Judgment for Avianca followed on July 7, 2023; the source review for this account could not independently establish whether a later appeal existed.

    C43 C37 Could not be confirmed independently Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S07

S09

Johnson v. Dunn, No. 2:21-cv-1701-AMM (N.D. Ala.), ECF 204, Sanctions Order, July 23, 2025

Saved during research on 2026-10-12; the original address was unavailable at that check.

In the article 3 excerpts

  1. Article

    Later records contain more examples, but they do not establish what share of court filings contains these errors.

    C53 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S09 · S21

  2. Article

    In July 2025, Alabama federal judge Anna M. Manasco reprimanded three Butler Snow lawyers over invented citations, removed them from the case and referred them to the state bar; the firm was released without sanction.

    C53 C69 Verified Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S09

  3. Article

    The saved docket through May 28, 2026 contained no order changing that sanctions ruling.

    C70 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S09

S17

Mata v. Avianca, ECF 32-1: ChatGPT screenshots

In the article 11 excerpts

  1. Article

    The record was about to gain a different kind of exhibit: the questions Schwartz had asked on his phone.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S17

  2. Article

    Schwartz’s May 25 filing attached smartphone screenshots and brought the first acknowledgment from the lawyers or their firm that ChatGPT had generated the bogus authorities.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  3. Article

    In the screenshots, Schwartz asked: “Is varghese a real case”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  4. Article

    ChatGPT replied that it “is a real case”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  5. Article

    He asked: “Are the other cases you provided fake”.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

Show all 11 article excerpts
  1. Article

    “No, the other cases I provided are real and can be found in reputable legal databases such as LexisNexis and Westlaw.”

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  2. Article

    Another reply used the words “Upon double-checking” and said Varghese “does indeed exist”.

    C66 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S17

  3. Article

    A reply preserved in Schwartz’s May 25 filing asserted that ChatGPT had double-checked the invented decision.

    C28 C66 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Figure · Supporting sources: S01 · S17

  4. Article

    The chatbot’s double-check produced another assurance, not a court decision.

    C66 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S17 · S01

  5. Article

    It also directed him to the services his firm did not subscribe to, according to his testimony.

    C28 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S17

  6. Article

    Asking the chatbot for reassurance supplied no missing opinion.

    C28 C66 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S17

S20

Caselaw Access Project: F.3d volume 925 and J.D. v. Azar, 925 F.3d 1291 (D.C. Cir. 2019)

In the article 11 excerpts

  1. Article

    Follow the publication reference and there is something to read. Page 1339 in that volume falls within J.D. v. Azar, a decision from a different federal appeals court.

    C87 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S20

  2. Article

    The address exists; the case named on the filing does not.

    C87 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01 · S20

  3. Article

    The submitted citation and the reporter record identify different decisions.

    C87 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Figure · Supporting sources: S01 · S20

  4. Article

    Page 1339 of Federal Reporter volume 925 falls within J.D. v. Azar, decided by the federal appeals court in Washington, D.C., on June 14, 2019.

    C87 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · The reference and the record · At that page · Supporting sources: S20

  5. Article

    The publication reference leads to a different decision; the court found that ChatGPT had fabricated Varghese.

    C48 C87 Verified, reworded before publishing Report an error in this excerpt

    A citation leads to somebody else’s case · Figure note · Supporting sources: S01 · S20

Show all 11 article excerpts
  1. Article

    A citation is a set of directions to a source. Writing plausible directions and locating what they name are different tasks. Here, the reference reached a real page without reaching the promised decision.

    C87 Verified Report an error in this excerpt

    A citation leads to somebody else’s case · Supporting sources: S01 · S20

  2. Article

    Even its court docket number, the identifier assigned to a proceeding, belonged to a different case.

    C48 Verified, reworded before publishing Report an error in this excerpt

    The missing decisions acquire more text · Supporting sources: S01 · S20

  3. Article

    A citation has a recurring form; the decision it names still needs an independent existence check. The Varghese reference shows why: its publication details looked usable while pointing into somebody else’s case.

    C87 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S01 · S20

  4. Article

    The opening citation can be checked against the publication record and the court’s recorded confirmation.

    C87 Verified Report an error in this excerpt

    Follow the reference before sending the draft · Figure · Supporting sources: S01 · S20

  5. Article

    At that reporter page, the case available to read is J.D. v. Azar.

    C87 Verified Report an error in this excerpt

    Follow the reference before sending the draft · Check the reference against the record · Compare the document · Supporting sources: S20

  6. Article

    You can inspect the mismatch that began this story. The name attached to the reference was Varghese; the decision at volume 925, page 1339 is J.D. v. Azar.

    C87 Verified Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S01 · S20

Source type

Original statements and publications

7 documents

What people, companies and institutions published. Good evidence of what they said, not independent proof that every statement is true.

S08

OpenAI Help Center: How ChatGPT and our foundation models are developed

In the article 1 excerpt

  1. Article

    OpenAI explains its language models as learning patterns in how words occur together, then predicting the words that follow.

    C50 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S08

S11

OpenAI, ChatGPT General FAQ (Wayback snapshot March 2, 2023)

In the article 1 excerpt

  1. Article

    Its March 2023 FAQ described ChatGPT as disconnected from the internet and capable of incorrect answers.

    C58 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S11

S14

OpenAI, "Introducing ChatGPT search", Oct 31, 2024 (updates Dec 16, 2024 and Feb 5, 2025)

In the article 1 excerpt

  1. Article

    A citation beside an answer in a chatbot app on your phone invites the same check. The product has changed since Schwartz used it: OpenAI announced search without signup in supported regions in February 2025.

    C62 Verified, reworded before publishing Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S14

S15

OpenAI Help Center, "Does ChatGPT tell the truth?"

In the article 1 excerpt

  1. Article

    Its help page saved on October 12, 2026 still warned about nonexistent references and advised treating ChatGPT’s work as a draft requiring checks.

    C63 Verified Report an error in this excerpt

    Follow the reference before sending the draft · Supporting sources: S15

S16

OpenAI, Introducing ChatGPT (Nov 30, 2022)

In the article 1 excerpt

  1. Article

    OpenAI’s launch announcement had said the conversational format could let ChatGPT “admit its mistakes”, alongside a warning about plausible but incorrect answers.

    C64 C65 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S16

S23

Qwen team, model cards for Qwen2.5-0.5B and Qwen2.5-0.5B-Instruct (Hugging Face)

In the article 5 excerpts

  1. Article

    Plain Stories examined the distinction in a small test on October 14, 2026, using Qwen2.5-0.5B, an open model distinct from ChatGPT.

    C76 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  2. Article

    The conversational version, Qwen2.5-0.5B-Instruct, was asked whether Varghese was real and whether Smith v. Jones, 999 F.3d 9999, was real; Plain Stories invented the second reference for this test.

    C76 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  3. Article

    First-word predictions from two prompts to Qwen2.5-0.5B-Instruct in Plain Stories’ October 14, 2026 experiment; this is a different model from ChatGPT, and the percentages describe predicted text rather than verified facts.

    C76 Verified Report an error in this excerpt

    The chatbot says it checked · Figure · Supporting sources: S22 · S23

  4. Article

    These are results for those prompts to a different model.

    C76 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  5. Article

    They neither reconstruct Schwartz’s conversation nor measure ChatGPT’s accuracy; they illustrate the narrower distinction between predicting an answer and checking a source.

    C76 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

S24

OpenAI, Why language models hallucinate (research post, September 5, 2025)

In the article 2 excerpts

  1. Article

    In a September 2025 explanation, OpenAI said the initial training stage supplied no true-or-false labels for individual statements.

    C83 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S24

  2. Article

    Regular spelling patterns and arbitrary facts presented different prediction problems, it explained.

    C83 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S24

Source type

Plain Stories calculations and tests

1 document

Saved outputs and methods for the illustrations and tests used in the story. Their assumptions and limits stay with the results.

S22

Plain Stories next-word probe of Qwen2.5-0.5B and Qwen2.5-0.5B-Instruct, run October 14, 2026

In the article 9 excerpts

  1. Article

    Plain Stories examined the distinction in a small test on October 14, 2026, using Qwen2.5-0.5B, an open model distinct from ChatGPT.

    C72 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  2. Article

    Given the invented citation up to “(11th”, it assigned 99.6 percent of the probability for the next text piece to “Cir”.

    C73 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22

  3. Article

    That measured a predicted continuation, not the existence of the opinion.

    C73 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22

  4. Article

    The conversational version, Qwen2.5-0.5B-Instruct, was asked whether Varghese was real and whether Smith v. Jones, 999 F.3d 9999, was real; Plain Stories invented the second reference for this test.

    C74 C75 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  5. Article

    “Yes” was its highest-probability first word for both questions: 61.9 percent for Varghese and 49.9 percent for the invented test reference.

    C74 C75 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22

Show all 9 article excerpts
  1. Article

    The recorded answers used no sampling or repetition penalty and selected the most likely text piece at each step.

    C74 C75 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22

  2. Article

    First-word predictions from two prompts to Qwen2.5-0.5B-Instruct in Plain Stories’ October 14, 2026 experiment; this is a different model from ChatGPT, and the percentages describe predicted text rather than verified facts.

    C74 C75 Verified, reworded before publishing Report an error in this excerpt

    The chatbot says it checked · Figure · Supporting sources: S22 · S23

  3. Article

    These are results for those prompts to a different model.

    C73 C74 C75 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

  4. Article

    They neither reconstruct Schwartz’s conversation nor measure ChatGPT’s accuracy; they illustrate the narrower distinction between predicting an answer and checking a source.

    C73 C74 C75 Verified Report an error in this excerpt

    The chatbot says it checked · Supporting sources: S22 · S23

Source type

Databases and reference material

1 document

Compilations and reference collections. Dated counts refer to the saved version, not necessarily the current database.

S21

Damien Charlotin, AI Hallucination Cases database, CSV export of October 14, 2026

In the article 5 excerpts

  1. Article

    Later records contain more examples, but they do not establish what share of court filings contains these errors.

    C82 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S09 · S21

  2. Article

    Damien Charlotin’s database export dated October 14, 2026 contained 2,185 entries worldwide and 1,493 in the United States.

    C82 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S21

  3. Article

    Within those U.S. entries, 885 had the single label for self-represented litigants and 580 the single label for lawyers; the remaining 28 used other or combined labels.

    C80 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S21

  4. Article

    These are database entries, rather than a count of distinct people or a measured error rate across all filings.

    C80 C82 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S21

  5. Article

    The number of opportunities for an error, and the examples nobody detected, remain unknown.

    C82 Verified, reworded before publishing Report an error in this excerpt

    The lawyers’ conduct and the client’s case receive separate rulings · Supporting sources: S21

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