An Am Law 100 firm submitted fake AI citations in two consecutive cases
Gordon Rees Scully Mansukhani apologized for submitting AI-hallucinated citations. A subsequent filing in another case was alleged to contain more fabricated authority.
The first apology is a training problem. The second one is a process problem.
Key facts
- What
- Gordon Rees Scully Mansukhani apologized for submitting AI-hallucinated citations.
- Incident date
- Sep 15, 2025
- Who
- Gordon Rees Scully Mansukhani
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- High
What happened
Gordon Rees Scully Mansukhani, an Am Law 100 firm with $759 million in 2024 gross revenue, apologized in 2025 for submitting briefs riddled with non-existent citations. A subsequent filing in Huynh v. Redis Labs in 2026 was alleged to contain additional fabricated authority. The case is the leading example of repeat AI-citation failure inside a top-tier law firm.
The first incident is a training problem. The second one is a process problem.
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.
Hallucination, same as Mata v. Avianca. What is new is the firm-level governance gap. The firm had received the lesson from the broader bar and from its own prior sanction, and the practice did not catch the next instance.
What it cost
Sources
- PressThe 2026 Legal AI Reckoningcompliancehub.wiki
- Press1,227 fabricated citations and countingblog.platinumids.com
Cite this entry
https://failureindex.ai/failures/gordon-rees-am-law-71-fake-citationsAI Failure Index. "An Am Law 100 firm submitted fake AI citations in two consecutive cases" (FI-0023). Realm Labs. https://failureindex.ai/failures/gordon-rees-am-law-71-fake-citations (indexed May 13, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0023. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
Realm sits between the AI tool and the brief. Every citation gets verified against an authoritative case-law system before the brief is filed. The runtime check makes the lesson stick at the firm level instead of relying on each attorney to remember it.