Levidow, Levidow and Oberman sanctioned for ChatGPT fabricated citations
Attorneys Schwartz and LoDuca of Levidow, Levidow & Oberman used ChatGPT to generate legal research, which produced six fake judicial opinions. The court sanctioned the firm and the attorneys with a $5,000 fine after the fabricated citations were discovered.
The AI generated plausible-sounding legal citations that did not exist in any judicial database.
Key facts
- What
- Attorneys Schwartz and LoDuca of Levidow, Levidow & Oberman used ChatGPT to generate legal research, which produced six fake judicial opinions.
- Incident date
- Jun 22, 2023
- Who
- Levidow, Levidow and Oberman
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Medium
What happened
Attorney Steven Schwartz and his firm submitted a court filing in Mata v. Avianca that included six fabricated citations generated by ChatGPT. The court discovered the fakes, and Judge P. Kevin Castel sanctioned the lawyers and their firm with a $5,000 fine.
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 root cause was the large language model generating fabricated but plausible-sounding citations. The attorneys did not verify the cited cases using traditional legal databases, allowing the misinformation to be submitted.
What it cost
Sources
- PressNew York lawyers sanctioned for using fake ChatGPT cases in legal briefreuters.com
- PressTwo US lawyers fined for submitting fake court citations generated by ChatGPTtheguardian.com
- Reader-SubmittedMata v. Avianca, Inc. - Wikipediaen.wikipedia.org
Cite this entry
https://failureindex.ai/failures/levidow-levidow-oberman-sanctioned-chatgpt-fabricatedAI Failure Index. "Levidow, Levidow and Oberman sanctioned for ChatGPT fabricated citations" (FI-0206). Realm Labs. https://failureindex.ai/failures/levidow-levidow-oberman-sanctioned-chatgpt-fabricated (indexed Jun 5, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0206. 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.