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Dehghani v. Castro

Court
D. New Mexico
Jurisdiction
USA
Decided
2025-04-02
AI tool
Unidentified
Outcome
Monetary sanction; required CLE on legal ethics and AI; mandatory self-reporting to NM and TX state bars; report of subcontractor to NY state bar; required notification to LAWCLERK
Monetary penalty
1500 USD

What was hallucinated

Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || Fabricated: Case Law | Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist. || False Quotes: Case Law | Counsel admitted that thirteen other citations quoted language not from the cited cases and did not support the stated propositions.

Details

AI UseCounsel hired a freelance attorney through LAWCLERK to prepare a filing. He made minimal edits and admitted not verifying any of the case law before signing. The filing included multiple fabricated cases and misquoted others. The court concluded these were AI hallucinations, likely produced by ChatGPT or similar.Hallucination DetailsExamples of non-existent cases cited include:Moncada v. Ruiz, Vega-Mendoza v. Homeland Security, Morales v. ICE Field Office Director, Meza v. United States Attorney General, Hernandez v. Sessions, and Ramirez v. DHS.All were either entirely fictitious or misquoted real decisions.Ruling/SanctionThe Court sanctioned Counsel by:Ordering a $1,500 fineRequiring a 1-hour CLE on AI/legal ethicsOrdering him to self-report to the New Mexico and Texas barsOrdering him to report the freelance lawyer to the New York barRequiring notification of LAWCLERKRequiring proof of compliance by May 15, 2025Key Judicial ReasoningThe court emphasized that counsel’s failure to verify cited cases, coupled with blind reliance on subcontracted work, constituted a violation of Rule 11(b)(2). The court analogized to other AI-sanctions cases. While the fine was modest, the court imposed significant procedural obligations to ensure deterrence.

Sanction teardown · D. New Mexico, USA · 2025-04-02

Dehghani v. Castro

What happened

In D. New Mexico, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • Fabricated (Case Law)
    Brief cited a non-existent case; Court and Respondent could not locate it, and counsel admitted it does not exist.
  • False Quotes (Case Law)
    Counsel admitted that thirteen other citations quoted language not from the cited cases and did not support the stated propositions.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Monetary sanction; required CLE on legal ethics and AI; mandatory self-reporting to NM and TX state bars; report of subcontractor to NY state bar; required notification to LAWCLERK (monetary penalty: 1500 USD.)

Additional detail

AI UseCounsel hired a freelance attorney through LAWCLERK to prepare a filing. He made minimal edits and admitted not verifying any of the case law before signing. The filing included multiple fabricated cases and misquoted others. The court concluded these were AI hallucinations, likely produced by ChatGPT or similar.Hallucination DetailsExamples of non-existent cases cited include:Moncada v. Ruiz, Vega-Mendoza v. Homeland Security, Morales v. ICE Field Office Director, Meza v. United States Attorney General, Hernandez v. Sessions, and Ramirez v. DHS.All were either entirely fictitious or misquoted real decisions.Ruling/SanctionThe Court sanctioned Counsel by:Ordering a $1,500 fineRequiring a 1-hour CLE on AI/legal ethicsOrdering him to self-report to the New Mexico and Texas barsOrdering him to report the freelance lawyer to the New York barRequiring notification of LAWCLERKRequiring proof of compliance by May 15, 2025Key Judicial ReasoningThe court emphasized that counsel’s failure to verify cited cases, coupled with blind reliance on subcontracted work, constituted a violation of Rule 11(b)(2). The court analogized to other AI-sanctions cases. While the fine was modest, the court imposed significant procedural obligations to ensure deterrence.

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/310/Dehghani_v_Castro_USA_New_Mexico_April_2_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/310/Dehghani_v_Castro_USA_New_Mexico_April_2_2025.pdf

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