Registry/APM-0040
Case No.
APM-0040
Subject
OpenAI
Filed
June 10, 2026
Severity
3 / 5 · MODERATE

Lawyers sanctioned after ChatGPT fabricated six fake case citations in Mata v. Avianca

Est. Damage ~$5k
Attribution Anonymous

Independent project · aggregated from public reports and may be unverified — see the primary source below · not affiliated with or endorsed by any company or product named.

In a personal-injury suit against Avianca, attorney Steven Schwartz used ChatGPT for research and submitted a brief citing six judicial decisions that did not exist — ChatGPT invented them and even 'confirmed' they were real when asked. U.S. District Judge Castel sanctioned Schwartz and co-counsel Peter LoDuca $5,000 and required corrective letters. It became the landmark cautionary tale about AI hallucination in legal filings.

Verified Facts

  • The brief cited six nonexistent cases generated by ChatGPT
  • ChatGPT 'confirmed' the fake cases when asked
  • Judge Castel imposed a $5,000 sanction in June 2023

Operational Lessons

  • Always verify AI-provided citations against primary sources
  • LLMs assert fabricated facts with confidence
Mata v. Avianca, Inc. (Wikipedia)en.wikipedia.org
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