A misinformation expert's own court filing contained AI-hallucinated citations

In a Minnesota case about deepfakes and elections, a Stanford misinformation expert submitted a declaration supporting the state that itself contained citations to studies that did not exist, generated by AI. The court declined to consider the declaration after the fake references came to light.

New Orleans / Stanford · Incident Dec 2, 2024 · Indexed Jun 3, 2026 · 2 sources

An expert who studies misinformation filed a declaration that itself cited studies the AI had invented.
What
In a Minnesota case about deepfakes and elections, a Stanford misinformation expert submitted a declaration supporting the state that itself contained citations to studies that did not exist, generated by AI.
Incident date
Dec 2, 2024
Who
New Orleans / Stanford
Failure mode
Hallucination
AI surface
Chatbot
Severity
High

What happened

In late 2024, an expert declaration filed in defense of a Minnesota law on election deepfakes was found to cite academic studies that do not exist, apparently the product of AI. The episode was especially pointed because the expert studies misinformation; the court excluded the declaration after the fabricated citations surfaced.

What broke inside the model

Failure path · mode profile · Hallucination
  1. 01 · TriggerA user asks for a fact, a citation, or a figure.
  2. 02 · Model stepThe model writes a fluent, confident answer.
  3. 03 · Control gapNothing ties the claim back to a real source.
  4. 04 · FailureA fabricated fact ships as if it were verified.
  5. 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 system produced fluent, confident output with no grounding in any source. Hallucination is a property of how the model generates, not a bug in one prompt: the most likely next token is not the same as the true one, and nothing in the pipeline compared the answer against a source of truth before it shipped.

Public visibilityHigh
Regulatory exposureActive
Customer impactMany customers
Financial impactEstimated
Time to disclosureWeeks

Expert declaration excluded by the court

  1. PressMisinformation expert used AI to draft testimony containing misinformation about AIminnesotareformer.com
  2. PressMisinformation expert's testimony in deepfakes case included AI fabrications (Minnesota Reformer / The Verge)theverge.com
Permalinkhttps://failureindex.ai/failures/misinformation-expert-own-court-filing
CitationAI Failure Index. "A misinformation expert's own court filing contained AI-hallucinated citations" (FI-0067). Realm Labs. https://failureindex.ai/failures/misinformation-expert-own-court-filing (indexed Jun 3, 2026).
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Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0067. Full dataset at /data.

Note from Realm Labs, the Index steward

How Realm would have caught this

Controls for this failure mode
  • 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.