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Despite over 2,000 court cases using fake AI-generated citations, Google pushes its AI legal assistance platform

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Google markets its AI-driven legal assistance platform “with centralised governance and control” as a complement to legal teams.

Meanwhile, over 2,000 instances of AI-generated fake citations in court decisions globally have been identified between April 2023 and September 2026.

Related: Here’s why police forces were told to stop using AI to prepare court statements

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AI Faked Citations In More Than 2,000 Cases As Google Pitches Legal Model

By Dylan Kresak, as published by the Daily Caller on 8 September 2026

Artificial intelligence (“AI”) continues to produce fake court citations as companies market their language models to law firms.

Generative AI hallucinations were listed in more than 2,000 court decisions [worldwide] since 2023, according to a public database created by legal researcher Damien Charlotin. At the same time, Google just promoted its legal AI tool as a “complement” to legal teams, according to an Axios interview released Tuesday.

“I view it as a complement, not a replacement,” Halimah DeLaine Prado, Google’s general counsel, told Axios. “The practice of law will always fundamentally rise and fall on the exercise of good judgment.”

DeLaine Prado added that AI already assists Google’s legal team with various tasks, such as contract redlining, e-discovery and litigation preparation, and she said these tools could make it easier for small law firms to compete with larger firms, according to Axios

Related: Trump Admin Splinters Over AI’s Right To Train On Americans’ Copyrighted Work

A spokesperson for Google’s Gemini Enterprise for Legal declined to comment before the time of publication.

“Last year saw, at first, an exponential rise in cases where people were caught hallucinating, but we have now reached a plateau,” Charlotin, a senior research fellow at HEC Paris, told the Daily Caller News Foundation (“DCNF”) about the findings of his AI hallucination research.

“[There are] several causes for this, amongst which [are] better tools and higher awareness,” Charlotin added. He explained that both frequency and severity of AI hallucinations have plateaued in the past year.

The data currently consists of 2,022 cases of AI-generated content, such as fake citations, used in legal decisions across the globe from April 2023 through 5 September 2026, according to Charlotin’s website. More than 1,300 were US cases. [69 were UK cases.]

Google’s AI models, specifically Gemini and Bard, were cited in a total of 10 cases, according to Charlotin’s data. ChatGPT was cited over 100 times.

Most cases resulted in a warning, with fewer than 160 cases resulting in disciplinary action, according to the data. Most fines for these incidents were between $1,000 and $5,000.

“[A]ll things otherwise equal, free LLMs [large language models], especially those that can’t search the Internet, hallucinate more as a baseline,” Charlotin told the DCNF. “Unfortunately, that’s also the kind of models self-represented litigants (the majority of cases in the database) tend to use.”

In one of the earliest cases in Charlotin’s data, two lawyers cited fake court cases in their legal brief that were generated by ChatGPT before being sanctioned by a New York federal judge.

“[T]he law firm of Levidow, Levidow & Oberman P.C. … abandoned their responsibilities when they submitted non-existent judicial opinions with fake quotes and citations created by the artificial intelligence tool ChatGPT,” the court stated in a June 2023 sanctions order.

Even after the court questioned whether the cases were real, the firm continued to defend them, according to the legal order.

Google launched Gemini Enterprise for Legal in August to perform legal tasks that the company said regular large language models (“LLMs”) cannot accomplish.

“Gemini Enterprise for Legal includes an open ecosystem that extends its capabilities with specialised [AI] agents like Deloitte Legal Assist, bringing deep legal experience to a platform with centralised governance and control,” Google Cloud said in a Sept. 5 X post promoting Gemini Enterprise. [Emphasis added]

The legal AI model provides “skills that enhance a firm’s own expertise, connections into the systems where matters actually live, agents that complete work rather than return suggestions, and an open ecosystem to extend all of its – with governance running underneath all four,” according to a n 25 August blog post from Thomas Kurian, CEO of Google Cloud.

About the Author

Dylan Kresak is a technology reporter for the Daily Caller News Foundation (“DCNF”). His work focuses on artificial intelligence, data centres, Big Tech, and the policy and national-security questions shaping America’s technology future. Prior to joining the DCNF, he wrote for The American Spectator through the National Journalism Centre.

Featured image taken from ‘Gemini Enterprise for Legal May Be the End of the Legal Industry’s Old Career Ladder’, Meme Burn, 27 August 2026

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Rhoda Wilson
While previously it was a hobby culminating in writing articles for Wikipedia (until things made a drastic and undeniable turn in 2020) and a few books for private consumption, since March 2020 I have become a full-time researcher and writer in reaction to the global takeover that came into full view with the introduction of covid-19. For most of my life, I have tried to raise awareness that a small group of people planned to take over the world for their own benefit. There was no way I was going to sit back quietly and simply let them do it once they made their final move.
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