CourseForward Deployed Engineer: The Complete Course · Module 5: AI and LLM Application Work · part 33 of 85
Part 33 · Module 5: AI and LLM Application Work

Incident: Invented citations, signed without checking

11 min read·13 Oct 2026
Module 5 · Incident file · About 35 minutes

What happened

Mata v. Avianca, 2023 1 Mar brief filed 15 Mar cases not found 25 Apr fake excerpts 22 Jun $5,000 penalty first admission of ChatGPT use: 25 May
Almost four months from the brief built on invented cases (amber) to sanctions (red); the cases were questioned on 15 March, two weeks after filing.

On 22 June 2023 Judge Castel of the US District Court for the Southern District of New York issued an Opinion and Order on Sanctions in Mata v. Avianca, Inc., No. 22-cv-1461 (PKC) (court record, ECF 54). Roberto Mata had sued the airline over a knee injury from a serving cart. On 1 March 2023 his lawyers filed an opposition to Avianca's motion to dismiss that "cited and quoted from purported judicial decisions".

On 15 March Avianca replied that it was "unable to locate most of the case law cited". The court ordered copies of the cases on 11 and 12 April. The affidavit filed on 25 April attached excerpts of opinions that did not exist. The first admission that the cases came from ChatGPT arrived on 25 May.

The cost, as ordered: a penalty of $5,000 "jointly and severally imposed" on the two lawyers and their firm, and a letter to their client and to "each judge falsely identified as the author of the fake" opinions. The court also listed harms that follow from fake opinions: the other side "wastes time and money", and the court's time "is taken from other important endeavors".

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