The firm relied on generative AI for legal research without human verification, resulting in citations to cases that do not exist—a phenomenon known as AI hallucination. The specific details of which cases were affected and the nature of the misrepresentations remain under seal. The court has not yet disclosed the attorney's name or specified what sanctions it may impose, though the summons signals serious consequences are under consideration.
This action follows a pattern of judicial rebukes across the country, including the 2023 Mata v. Avianca case in New York, where attorneys were disqualified for citing nonexistent cases generated by ChatGPT, and a recent federal sanction in Maine against a Massachusetts lawyer for similar AI-generated citation errors. Connecticut established a Committee on Artificial Intelligence in the Legal System to monitor the issue, but this order suggests the court is moving beyond study to enforcement. Attorneys should assume that courts will no longer tolerate unverified AI research in pleadings and that sanctions—potentially including disqualification—are now a realistic consequence of such lapses.