Manhattan Lawyers Sanctioned for Submitting ChatGPT-Fabricated Case Citations
Federal judge sanctioned attorneys Steven Schwartz and Peter LoDuca after they submitted a brief in Mata v. Avianca containing six entirely-fabricated case citations generated by ChatGPT.
In June 2023, U.S. District Judge P. Kevin Castel of the Southern District of New York sanctioned attorneys Steven Schwartz and Peter LoDuca, and their law firm Levidow, Levidow & Oberman, $5,000 in fines after they submitted a brief in Mata v. Avianca Inc. (1:22-cv-01461) containing six entirely fabricated case citations that ChatGPT had hallucinated. Schwartz testified he had asked ChatGPT to confirm the cases were real and the model insisted they existed. Judge Castel called the conduct 'an unprecedented circumstance' and emphasised that technology was 'not inherently improper' — the failure was the lawyers' inability to verify. The case became a foundational reference for legal-tech AI governance and prompted state bar associations across the U.S. to issue advisory guidance on LLM use in litigation.
Systems & Vendors Implicated
What EvalGuard would have caught
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