Anonymous v. NYC Department of Education

Hallucinated Content

Outcome

Notes

AI UseThe plaintiff, proceeding pro se, submitted filings citing multiple nonexistent cases. The court noted patterns typical of ChatGPT hallucinations, referencing studies and prior cases involving AI errors, though the plaintiff did not admit using AI.Hallucination DetailsSeveral fake citations identified, including invented federal cases and misquoted Supreme Court opinions. Defendants flagged these to the court, and the court independently confirmed they were fictitious.Ruling/SanctionNo sanctions imposed at this stage, citing special solicitude for pro se litigants. However, the court issued a formal warning: further false citations would lead to sanctions without additional leniency.Key Judicial ReasoningThe court emphasized that even pro se parties must comply with procedural and substantive law, including truthfulness in court filings. Cited Mata v. Avianca and Park v. Kim as established examples where AI-generated hallucinations resulted in sanctions for attorneys, underscoring the seriousness of the misconduct.