Warning: Generative AI may hallucinate citations, result in discipline

FOR IMMEDIATE RELEASE: 12-9-2025

Contact: Danny Shapiro, public relations manager

Phone: 602.340.7337

Email: danny.shapiro@staff.azbar.org

Warning: Generative AI may hallucinate citations, result in discipline

Generative AI has transformed how the legal world operates, but using the technology properly is a necessity.

Legal professionals in Arizona have increasingly been using AI to create pleadings, motions and briefs - and some contain hallucinated citations. In other words, AI is creating fake sources that are presented as factual. Sometimes, these hallucinated citations have portions of factual information but are not wholly correct. Issues with hallucinated citations have been found in ChatGPT, Microsoft Copilot, Google Gemini and other AI models.

This conduct may lead to disciplinary action by the State Bar of Arizona. Several cases have already made their way to the Bar.

Thankfully, there are ways to use generative AI correctly and avoid the discipline process.

The State Bar of Arizona’s best practices for using generative AI outline practice guidance in several ways. The Bar notes that legal professionals must exercise caution, critical analysis and independent judgment when integrating AI into their practice in order to comply with professional responsibility obligations.

For more information on generative AI, read here.

About the State Bar
The State Bar of Arizona is a nonprofit organization that operates under the supervision of the Arizona Supreme Court. The Bar includes more than 19,000 active attorneys and provides education and development programs for the legal profession and the public. Since 1933, the Bar and its members have been committed to serving the public by making sure the voices of all people in Arizona are heard in our justice system.

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Warning: Generative AI may hallucinate citations, result in discipline

Warning: Generative AI may hallucinate citations, result in discipline

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