So in Zelma v. Wonder Group, Inc. 2025 WL 2976546 (D. N.J. Oct. 22, 2025) the Plaintiff appears to have used AI to generate a brief opposing Plaintiff’s motion to dismiss. (Seems like a category 2 situation since Plaintiff isn’t a lawyer.)
Here is what the Court said on the subject (this is long but good):
Plaintiff included fabricated quotations from real cases, and at other points, cited to cases that, to the best of the Court’s knowledge, do not exist. See id.
Accordingly, Plaintiff was ordered to disclose whether he used any generative artificial intelligence while drafting his Opposition and explain the identified discrepancies. Id. In his response, Plaintiff stated that he saw a “wave of Al-based services” when conducting legal research for this matter, and even tested one of the platforms for “off topic input.” D.E. 19-2 (“Plaintiff’s Letter”) at 1. However, this experience “reinforced [his] decision to rely on [his] personal TCPA archive and trust legal databases.” Id
Plaintiff explained the fabricated quotations in his Opposition by stating that he “inadvertently used quotation marks in places where [he] meant only to paraphrase a holding or summarize the spirit of a ruling,” which he now “understand[s] … could misrepresent intent and mislead the Court.” Id. at 2. According to Plaintiff, he had “always used quotes where a supporting statement is made,” but he “now understand[s] the difference between citation and paraphrasing.” Id. And while Plaintiff acknowledged that “some of the cases [he] originally cited can’t be found or verified in official records,” he chalked that up to either “misread[ing] the source or summariz[ing] it poorly.” Id.
Plaintiff’s explanation strains credulity. Plaintiff has, in this district alone, brought nearly two dozen cases. Thus, despite his pro se status, he is not an inexperienced litigant. Plaintiff’s submissions in this case alone demonstrate a familiarity with caselaw and pleading requirements. He even has a database of TCPA cases. If Plaintiff has enough repeat litigation to maintain a compendium of relevant cases, and has even learned how to properly Bluebook his citations, surely he knows how to use quotation marks…
Plaintiff’s above explanation does not fully account for the fabricated quotations and citations within his brief. It also calls into serious doubt the certification attached to his Opposition, in which Plaintiff declared under the penalty of perjury that he reviewed all relevant law, rules and regulations relevant to this matter. D.E. 9-1. The Court will defer its decision on whether to impose any sanctions against Plaintiff until the conclusion of this litigation.
So… yeah.
AI makes up cases. Makes up quotes.
And lawyers think they should use this?