NY Lawyer Files Federal Brief With 6 Made-Up Cases ChatGPT Invented — Including 'Varghese v. China Southern' With a Fake Opinion Written by a Real Judge

In May 2023, Steven Schwartz, a 30-year veteran New York attorney, filed a 10-page brief in Mata v. Avianca that cited six prior cases — every single one completely fabricated by ChatGPT. The bot had even written fake 'opinions' attributed to real federal judges. When the airline's lawyers couldn't find the cases, Schwartz asked ChatGPT if they were real. It said yes and generated more fake excerpts. Judge Castel sanctioned Schwartz and his firm $5,000 and forced a formal apology to every judge ChatGPT had falsely cited. The case became the founding legal precedent for AI hallucination liability in US courts.