Published opinion, 4 August 2026 · source · PDF · 9 pages
(SC 21184) July 31, 2026 PER CURIAM. We are required to confront for the first time a lawyer’s use of generative artificial intelli- gence (generative AI) that has resulted in the submission of written materials to this court containing citations that were “hallucinated”—in other words, fabricated or inaccurately generated. Attorney Ian G.
Gottlieb and GLG Law, LLC (law firm), filed applications for certifi- cation to file public interest appeals in accordance with General Statutes § 52-265a in the two cases at issue. The applications included citations that were “hallucinated” because of the use of generative AI during the editing and review process. After the Chief Justice granted those applications, Attorney Gottlieb submitted briefs in each of these cases that also contained hallucinated citations.
Unbeknownst to Attorney Gottlieb, the drafts produced by ChatGPT added new case citations or altered existing case cita- tions, making the final documents filed in this court inaccurate and misleading. Because the hallucinations created by ChatGPT did not affect the substantive accu- racy of the legal propositions contained within the fil- ings, which remained well established and correct, the AI generated changes did not prompt Attorney Gottlieb or his law firm colleagues who reviewed the documents to verify the supporting citations a second time. Attorney Gottlieb became aware of the erroneous citations only when various amici curiae, represented by the Jerome N.
Attorney Gottlieb became aware of the erroneous citations only when various amici curiae, represented by the Jerome N. Frank Legal Services Organization, apprised this court and counsel of what appeared to be “hallucinated” case citations in the briefs. Attorney Gottlieb subsequently filed errata sheets and corrected the briefs in both cases.
ORDERS355 Conn. 907 this case, we are mindful that the hallucinated citations resulted from negligence in the use of new technology, rather than an intentional attempt to deceive or mislead this court or other parties, Attorney Gottlieb did not have a dishonest or selfish motive, he cooperated with the disciplinary process by honestly and forthrightly responding to our requests seeking further information and understanding regarding the erroneous citations, he admitted his mistake, he showed sincere contrition, and he has no disciplinary history. Nevertheless, the submis- sion of erroneous citations in violation of the Rules of Professional Conduct is not something we take lightly.