U.S. Judge Declines to Sanction Buchalter Over AI-Generated Case Citations in Court Filing

A federal judge in Oregon chose not to sanction Buchalter after its lawyers unknowingly included AI-generated case citations, recognizing the firm’s remedial actions and policy review.

A federal judge in Oregon has decided not to impose formal sanctions on U.S. law firm Buchalter after the firm submitted court filings containing AI-generated case citations.

The ruling comes amid growing scrutiny over the use of artificial intelligence in legal research and document preparation.

Judge Michael Simon in Portland stated that the firm’s response to the incident was sufficient and showed accountability.
The court acknowledged that Buchalter took prompt steps to address the mistake and prevent future misuse of AI tools in its legal work.

The law firm outlined several corrective measures in its filings earlier this week.

These included donating $5,000 to a local organization supporting legal aid providers and reviewing internal safeguards to ensure compliance with ethical standards.

Buchalter also offered to reimburse any legal fees incurred by its client or opposing counsel due to the erroneous citations.

These actions, according to the judge, demonstrated a sincere effort to uphold professional integrity and restore confidence in the legal process.

Buchalter, a firm with nearly 600 lawyers across multiple U.S. offices, is among several law firms recently examined by courts for improper use of AI tools.

The growing reliance on generative AI has raised concerns about the accuracy of legal documents and the potential for “hallucinated” or fabricated citations.

In this case, the issue arose during a trademark dispute between Green Building Initiative, a nonprofit promoting sustainable construction, and Green Globe Limited.

Buchalter, along with co-counsel from Snell & Wilmer, represented the Green Building Initiative in the case.

Last month, Judge Simon asked the attorneys to explain why they should not face sanctions after discovering two non-existent case citations in their filing.

One citation was entirely fabricated, while another referred to a real case but misrepresented its content.

The lawyers promptly apologized and submitted an explanation to the court.

Senior associate David Bernstein acknowledged that he had used AI software to edit the document, which unintentionally inserted the false citations.

Bernstein said he had initially completed his own legal research and used the AI tool solely to refine the document’s writing style.

He admitted, however, that he failed to review the final version thoroughly before submission, leading to the inclusion of inaccurate case references.

In his declaration, Bernstein expressed deep regret for the mistake and apologized to the judge, clients, and all parties involved.

He emphasized that the incident was unintentional and that the firm has strict policies governing the responsible use of AI technology.

Buchalter later issued a public statement reaffirming its commitment to ethical standards in legal practice.

The firm described the incident as a clear violation of its internal policies, which prohibit the unverified use of generative AI in client-related work.

Legal experts note that this case highlights both the promise and risk of AI in professional services.

While AI tools can enhance efficiency and productivity, they also require human oversight to ensure accuracy and accountability.

Judge Simon’s decision reflects a balanced approach, acknowledging the firm’s transparency and swift corrective measures.

By opting against sanctions, the court underscored the importance of learning and adaptation as new technologies reshape legal practice.

As the legal industry increasingly adopts AI tools for research and drafting, firms are revising policies to manage potential errors.

The Buchalter case serves as a cautionary example for lawyers to verify AI-generated content before submission to courts or clients.

The incident also signals the judiciary’s evolving stance toward technology-driven errors in legal documentation.

Rather than imposing penalties, courts may favor remediation and education to promote responsible innovation in law.