Dehghani v. Castro attorneys sanctioned for AI hallucinations
A filing attorney and a freelance attorney in the case of Dehghani v. Castro were sanctioned by a New Mexico federal court for submitting a brief containing AI-generated hallucinations. The court imposed fines, mandatory continuing legal education (CLE) training, and a requirement to self-report the misconduct to their respective state bars.
A freelance attorney likely used GenAI and then destroyed all notes, while the purchasing attorney failed to review the brief before submission.
Key facts
- What
- A filing attorney and a freelance attorney in the case of Dehghani v.
- Incident date
- Apr 2, 2025
- Who
- Attorneys in Dehghani v. Castro
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- High
What happened
In the Dehghani v. Castro matter in the U.S. District Court for the District of New Mexico, a filing attorney purchased a legal brief from a freelance attorney who used generative AI to draft the document. The brief contained AI-generated hallucinations and fictitious citations. The filing attorney submitted the brief without performing due verification of the citations, and sanctions were imposed on both the filing attorney and the freelance attorney, including fines, mandatory CLE training, and self-reporting to state bars.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
The generative AI model produced plausible-sounding but non-existent legal citations and fabricated case law. Human review failed to verify the AI output against authentic records, allowing the misinformation to be submitted to the court.
What it cost
Sources
- PressAI IP Year in Review - AI Hallucinations in Court Filings and Orderssternekessler.com
- Court FilingDEHGHANI v CASTRO (D.N.M. 2025) - Justialaw.justia.com
- PressAZADEH DEHGHANI v. DORA CASTRO (2025) - FindLawcaselaw.findlaw.com
Cite this entry
https://failureindex.ai/failures/dehghani-castro-attorneys-sanctioned-hallucinationsAI Failure Index. "Dehghani v. Castro attorneys sanctioned for AI hallucinations" (FI-0267). Realm Labs. https://failureindex.ai/failures/dehghani-castro-attorneys-sanctioned-hallucinations (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0267. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.