The Georgia Court of Appeals has imposed the maximum penalty on an Atlanta divorce attorney after finding that she cited nonexistent legal cases in a court filing, an error that judges suggested may have been the result of artificial intelligence “hallucinations.”

The attorney, Diana Lynch, was fined $2,500 after a panel of appellate judges determined that her motion included references to multiple cases that either did not exist or were irrelevant to her argument. The ruling, obtained by The New York Times, described the citations as deeply problematic, undermining the integrity of the judicial process.

The Case in Question

The issue arose during a contentious divorce proceeding in which Lynch represented one of the parties. After her client’s ex-wife flagged several suspicious case citations, the court discovered that half of the legal precedents Lynch had referenced appeared to be fabricated—a phenomenon known in A.I. parlance as “hallucinations.” The remaining cases bore no relation to the legal argument she had presented.

When confronted, Lynch allegedly doubled down, submitting nearly a dozen additional references that were either fictitious or irrelevant. She then sought legal fees related to the appeal, a move that further drew the court’s ire.

Judges Express Alarm

In their ruling, the appellate judges, led by Judge Jeff Watkins, wrote that they were “troubled” by the submission of bogus cases, which deprived the opposing party of a fair chance to respond.

“Lynch’s use of fictitious cases and citations has deprived the opposing party of the opportunity to appropriately respond to her arguments,” the judges wrote.

They also pointed to a warning issued by U.S. Supreme Court Chief Justice John Roberts in his 2023 year-end report on the federal judiciary, in which he cautioned lawyers about the risks of relying on generative A.I. tools that can produce false or misleading legal references.

A Growing Concern in Legal Circles

The incident highlights a growing challenge for the legal profession as artificial intelligence becomes more widely used in research and drafting. While A.I. can streamline legal work, its tendency to “hallucinate” plausible-sounding but false information has led to multiple instances of attorneys unwittingly submitting fabricated cases in court filings.

Last year, a New York lawyer was sanctioned for submitting a brief laden with fictitious citations generated by ChatGPT, prompting state and federal courts to adopt stricter verification rules.

What Happens Next

The court vacated the original order in Lynch’s case and sent it back to a lower court for reconsideration. The $2,500 fine represents the maximum penalty allowable under Georgia law for such an offense.

Legal experts say the ruling serves as a stark reminder that attorneys remain ultimately responsible for the accuracy of their submissions—regardless of whether A.I. tools were involved.

Lynch has not yet commented on the ruling. It remains unclear whether she plans to appeal the fine or whether disciplinary action from the state bar could follow.

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