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Federal Judge Finds DOJ Cited a Nonexistent Case Likely Created by AI

The ruling warns lawyers they must verify AI-produced citations or face possible sanctions as courts confront recurring 'hallucinations'.

Overview

  • Chief U.S. District Judge Hala Y. Jarbou wrote this week that a case the DOJ cited—Taylor v. Hott—does not exist and the referenced Federal Appendix page contains an unrelated opinion.
  • Jarbou said the citation appears to be a product of generative artificial intelligence and ordered the government to ensure future filings do not include nonexistent case law.
  • Court metadata show each government filing in the matter was submitted by Acting Attorney General Todd Blanche, tying the error to a high-level DOJ filing.
  • The judge admonished DOJ attorneys, invoked the duty of candor, declined to impose sanctions now, and warned that penalties remain possible if the conduct repeats.
  • The underlying habeas action concerned an ICE detainee’s $35,000 bond; the petition was dismissed as moot after a 90-day automatic stay expired and the government said the bond can be posted, and the episode adds to a wider pattern of AI citation errors and debate over DOJ staffing and review practices.