Lifetime Well LLC v. IBSpot.com Inc.
- Party
- Lawyer
- AI Tool
- Lexis+ AI; LexisNexis Protégé
Hallucinated Content
Fabricated
- Case Law
Multiple AI-generated, non-existent case opinions were cited in the Motion; Court identified eight defective citations.
False Quotes
- Case Law
Motion included an alleged quotation that does not appear in the cited opinion; opposing counsel flagged the nonexistent quote from a Pennsylvania case.
Misrepresented
- Case Law
Several real cases were cited but did not support the propositions asserted or were from inapposite jurisdictions (mischaracterized holdings).
Outcome
Notes
"Judges and commentators continue to warn lawyers about the risks of artificial intelligence shortcuts. We today address a more fundamental concern: lack of diligence and supervision of less experienced lawyers who can fairly expect supervision. The lawyers disregarded basic fundamental understandings learned in law school about the need to ensure the case citations presented to judges support what lawyers say they do. Counsel fell far short of this fundamental obligation warranting monetary sanctions against the New York co-counsel and non-monetary sanctions against both the New York co-counsel and her local Philadelphia co-counsel.Attorneys are again forewarned. Judges and their talented lawyers in Chambers scrutinize memoranda. Submissions containing unverified authority divert limited resources from other litigants who rely on their advocates’ careful research, accurate citation, and disciplined advocacy. These sanctions serve as a reminder the attorney’s oath of admission demands no less."