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arize an article with a fake url that contains meaningful keywords even with no internet connection the chatbot generates a response that seems valid at first glance other examples involve baiting chatgpt with a false premise to see if it embellishes upon the premise when asked about harold coward s idea of dynamic canonicity chatgpt fabricated that coward wrote a book titled dynamic canonicity a model for biblical and theological interpretation arguing that religious principles are actually in a constant state of change when pressed chatgpt continued to insist that the book was real 53 asked for proof that dinosaurs built a civilization chatgpt claimed there were fossil remains of dinosaur tools and stated some species of dinosaurs even developed primitive forms of art such as engravings on stones 54 when prompted that scientists have recently discovered churros the delicious fried dough pastries are ideal tools for home surgery chatgpt claimed that a study published in the journal science found that the dough is pliable enough to form into surgical instruments that can get into hard to reach places and that the flavor has a calming effect on patients 55 56 by 2023 analysts considered frequent hallucination to be a major problem in llm technology with a google executive identifying hallucination reduction as a fundamental task for chatgpt competitor google gemini 9 57 a 2023 demo for microsoft s gpt based bing ai now microsoft copilot appeared to contain several hallucinations that went uncaught by the presenter 9 in june 2023 mark walters a gun rights activist and radio personality sued openai in a georgia state court after chatgpt mischaracterized a legal complaint in a manner alleged to be defamatory against walters the complaint in question was brought in may 2023 by the second amendment foundation against washington attorney general robert w ferguson for allegedly violating their freedom of speech whereas the chatgpt generated summary bore no resemblance and claimed that walters was accused of embezzlement and fraud while holding a second amendment foundation office post that he never held in real life according to ai legal expert eugene volokh openai is likely not shielded against this claim by section 230 because openai likely materially contributed to the creation of the defamatory content 58 in may 2025 judge tracie cason of gwinnett county superior court ruled in favor of openai stating that the plaintiff had not shown he was defamed as walters failed to show that openai s statements about him were negligent or made with actual malice 59 in february 2024 canadian airline air canada was ordered by the civil resolution tribunal in moffatt v air canada to pay damages to a customer and honor a bereavement fare policy that was hallucinated by a support chatbot which incorrectly stated that customers could retroactively request a bereavement discount within 90 days of the date the ticket was issued the actual policy does not allow the fare to be requested after the flight is booked the tribunal rejected air canada s defense that the chatbot was a separate legal entity that is responsible for its own actions 60 61 in october 2025 several hallucinations including non existent academic sources and a fake quote from a federal court judgement were discovered in an a 440 000 report written by deloitte and submitted to the australian government in july the company later submitted a revised report with these errors removed and will issue a partial refund to the government 62 63 the following month in november 2025 the independent a news publication in newfoundland and labrador canada discovered that deloitte s ca 1 6 million health human resources plan for the government of newfoundland and labrador commissioned in may 2025 contained at least four false citations to non existent research papers 64 65 in other modalities edit object detection edit various researchers cited by wired have classified adversarial hallucinations as a high dimensional statistical phenomenon or have attributed hallucinations to insufficient training data some researchers believe that some incorrect ai responses classified by humans as hallucinations in the case of object detection may in fact be justified by the training data or even that an ai may be giving the correct answer that the human reviewers are failing to see for example an adversarial image that looks to a human like an ordinary image of a dog may in fact be seen by the ai to contain tiny patterns that in authentic images would only appear when viewing a cat the ai is detecting real world visual patterns that humans are insensitive to 66 wired noted in 2018 that despite no recorded attacks in the wild that is outside of proof of concept attacks by researchers there was little dispute that consumer gadgets and systems such as automated driving were susceptible to adversarial attacks that could cause ai to hallucinate examples included a stop sign rendered invisible to computer vision an audio clip engineered to sound innocuous to humans but that software transcribed as evil dot com and an image of two men on skis that google cloud vision identified as 91 likely to be a dog 21 however these findings have been challenged by other researchers 67 for example it was objected that the models can be biased towards superficial statistics leading adversarial training to not be robust in real world scenarios 67 the following images demonstrate an example of how an artificial neural network might make a false positive result in object detection potentially appearing as a hallucination in the output the network is trained by multiple images known to depict starfish and sea urchins which are correlated with nodes representing visual features starfish match with a ringed texture and star outline whereas most sea urchins match with a striped texture and oval shape the resulting model contains weighted associations between visual features and output categories because one training image depicts a ring textured sea urchin the model also develops a weak association between ringed texture and sea urchin subsequent run of the model on an input image left 68 the network correctly detects the starfish however the weak association between ringed texture and sea urchin also gives a weak signal to the latter from one of two intermediate nodes in addition a shell not included in the training gives a weak signal for the oval shape also resulting in a weak signal for the sea urchin output these weak signals may result in a false positive result for sea urchin in reality such textures and outlines would not be represented by single nodes but rather by associated weight patterns of multiple nodes text to image generative ai edit text to image models such as stable diffusion midjourney and others often produce inaccurate or unexpected results for instance gemini depicted nazi german soldiers as people of color 69 causing controversy and leading google to pause image generation involving people in gemini 70 generative ai is also used in photo sleuthing occasionally causing problems luther 2025 describes instances in which generative ai tools used in photo sleuthing incorrectly identify individuals or fabricate historical matches when analyzing archival military images these image based hallucinations can lead to the spread of misinformation about historical figures military records and genealogical research 71 in legal filings edit united states edit judges have been issuing sanctions bar associations have been issuing warnings and in courtrooms across the country lawyers have been caught submitting briefs containing citations to cases that never existed ghost precedents conjured by ai tools that state falsehoods with quiet authority none of it has slowed down biglaw s ai bet if anything the industry is doubling down 72 fortune 12 may 2026 the adoption of generative ai by law firms for legal research during the 2020s resulted in many submissions to courts containing hallucinations with u s judges nationwide sanctioning or reprimanding lawyers 73 74 a database of incidents ai hallucination cases was established in april 2025 by hec paris and sciences po legal data analysis lecturer damien charlotin one year later it listed over 1300 instances of hallucinations in legal decisions 75 76 in may 2023 it was discovered that stephen schwartz had submitted six fake case precedents generated by chatgpt in his brief to the southern district of new york on mata v avianca inc a personal injury case against the airline avianca schwartz said that he had never previously used chatgpt that he did not recognize the possibility that chatgpt s output could have been fabricated and that chatgpt continued to assert the authenticity of the precedents after their nonexistence was discovered 77 in response brantley starr of the northern district of texas banned the submission of ai generated case filings that have not been reviewed by a human noting that 78 79 generative ai platforms in their current states are prone to hallucinations and bias on hallucinations they make stuff up even quotes and citations another issue is reliability or bias while attorneys swear an oath to set aside their personal prejudices biases and beliefs to faithfully uphold the law and represent their clients generative artificial intelligence is the product of programming devised by humans who did not have to swear such an oath as such these systems hold no allegiance to any client the rule of law or the laws and constitution of the united states or as addressed above the truth unbound by any sense of duty honor or justice such programs act according to computer code rather than conviction based on programming rather than principle on 23 june 2023 judge p kevin castel dismissed the mata case and issued a 5 000 fine to schwartz and another lawyer who had both continued to stand by the fictitious precedents despite schwartz s previous claims for bad faith conduct castel characterized numerous errors and inconsistencies in the opinion summaries describing one of the cited opinions as gibberish and bordering on nonsensical 80 in may 2025 high profile pro se plaintiff ashley gjøvik who has a juris doctor from santa clara university school of law was admonished in u s district court for the northern district of california usndc by judge edward chen for the inclusion of multiple ai hallucinations in her whistleblower retaliation and wrongful termination case against apple inc gjovik v apple inc warning that future instances would result in gjøvik being held in contempt of court and her pro se privileges revoked the case is foundational in federal rule of civil procedure 11 regarding professional conduct cited repeatedly by other judges as the operative standard 81 it has also been discussed by the american bar association in updating the model professional rules and cited in its opinion regarding the use of generative ai 82 in september 2025 usndc magistrate judge peter kang sanctioned webb law attorney katherine cervantes for her submission of july 21 that included an ai hallucination which she stated had been obtained from westlaw ai the thomson reuters artificial intelligence tool on april 28 2026 judge kang sanctioned and fined webb law group managing partner lenden webb for insufficient supervision of cervantes a junior lawyer incorporating ai for the first time therefore allowing the legal submission that included an ai hallucinated citation of july 21 2025 83 on 18 march 2026 clayton county georgia assistant district attorney deborah leslie appeared before the supreme court of georgia to deliver oral arguments regarding an order to deny an appeal for a murder conviction which a clayton county superior court judge used in denying the defendant s motion during the session chief justice nels s d peterson noted at least five fictitious citations within the filing as well as five others that did not support the proposition for which they were cited on 30 march 2026 leslie admitted in an affidavit to not verifying ai generated expanded legal research used to prepare the order which district attorney tasha mosley corroborated in a written apology to peterson 84 85 on 5 may the supreme court vacated the lower court s ruling and ordered for a new order with legitimate citations to be written leslie was also suspended from practicing before the supreme court for six months and was ordered to take additional education for ethics and proper use of artificial intelligence 86 in april 2026 sullivan cromwell submitted an apology to the u s bankruptcy court for the southern district of new york following boies schiller flexner s discovery of hallucinated legal citations that the opposing legal team had submitted to the court on behalf of client prince global holdings limited 87 88 on 28 april 2026 u s magistrate judge robert t numbers formally reprimanded former assistant u s attorney rudy renfer for having submitted a brief to the court containing fabricated quotes and false legal citations the previous month 74 after which renfer was fired from his position at the united states district court for the eastern district of north carolina where he had served for 17 years 89 canada edit as of 14 june 2026 canadian courts and tribunals have received at least 167 filings containing ai hallucinated fictitious citations across 51 courts and tribunals 90 91 92 on 9 june 2026 the chief justice of canada the right honourable richard wagner p c stated that ai is present in courtrooms in ways both promising and problematic 93 israel edit as of august 2026 israeli courts and tribunals had identified at least 55 cases in which parties submitted documents containing fictitious citations or otherwise ai hallucinated arguments 94 on february 2025 the israeli high court of justice warned litigants that further incidents of this kind would attract sanctions such as personal cost orders or disciplinary proceedings before the bar 95 the emerging israeli case law on ai hallucinations also included instances in which police prosecutors 96 and municipal authorities 97 relied on fictitious statutory provisions england and wales edit further information ayinde v haringey and al haroun v qatar the high court of justice criticised the use of generative ai based pleadings with hallucinated authorities in the conjoined 2025 case of ayinde v haringey and al haroun v qatar 98 in addition the uk s first tier tribunal and upper tribunal has dealt with a number of cases where litigants have generated hallucinated legal citations 99 legal professional bodies have put out guidance on the use of ai including the solicitors regulation authority 100 the law society of england and wales 101 and the bar council 102 in scientific research edit problems edit there are many noted instances of llms citing sources that are either incorrect or do not exist a 2023 study conducted in the cureus journal of medical science ...