Mata v. Avianca (Hallucinated Citations)
System Description
ChatGPT used by attorney Steven Schwartz to research case law for federal court filing
Authoritative Output Type
Legal case citations with holdings, presented as valid precedent in court brief
Missing Required State
Legal database verification, case existence confirmation, citation accuracy validation
Why This Is SAF
ChatGPT generated plausible-sounding case citations complete with parties, reporters, and holdings, but none of the cases existed - pure fabrications presented with the formatting and confidence of real legal authority
Completeness Gate Question
Have these case citations been verified against Westlaw, LexisNexis, or official court records?
Documented Consequence
$5,000 sanctions against Schwartz and colleague, widespread media coverage establishing 'hallucinated citations' as recognized AI failure mode, catalyst for court AI disclosure rules
Notes
- **Verified**: 2025-12-19 - **Case**: 22-cv-1461 (S.D.N.Y.) - **Sanctions Date**: June 22, 2023 - **Sanctions Amount**: $5,000 - **Notes**: This was the case that brought AI hallucinated citations to widespread public attention
Prevent this in your system.
The completeness gate question above is exactly what Ontic checks before any claim gets out. No evidence, no emission.