Business Is Apparently Selling AI-Hallucination-Filled Documents to Unwary Litigants, Court Says |
AI in Court
Eugene Volokh | 1.16.2026 3:05 PM
From Judge Michael Liburdi (D. Ariz.) last Friday in Gardner v. Nationstar Mortgage LLC:
Through these proceedings, brought by Plaintiff to halt a foreclosure of her home, the Court learned of non-party document preparers seeming to hold themselves out as attorneys and using undisclosed artificial intelligence platforms ("AI") to draft documents used in this litigation on Plaintiff's behalf. By all appearances, these document preparers purported to help her prevent foreclosure of her home while diverting funds she could have used towards the mortgage payment it and preparing claims without legal basis for Plaintiff to file.
Thus, the Court brings the matter to the attention of the State Bar of Arizona and the Attorney General of Arizona. The Court instructs the Clerk of Court to provide a copy of this order to each for investigation, if appropriate, and such further action as these entities deem necessary….
After the death of her husband, Plaintiff took over the financial responsibilities of her household; as a result, she faced foreclosure and initiated this action. A recognized title company referred Plaintiff to Clearpoint. Fearful of losing her home, Plaintiff hired Clearpoint to prepare her legal documents.
Plaintiff did not understand any of the legal documents she submitted to the Court and followed instructions from Clearpoint throughout the litigation process because her contacts called themselves the "Litigation Team." … After removing the case [to federal court], Nationstar filed responsive pleadings, in which it highlighted over sixty instances of inapplicable law, nonexistent cases or legal principles, and misconstrued holdings and quotations in Plaintiff's Complaint and Amended Motion for Preliminary Injunction.
The Court then issued an Order to Show Cause for why her motion should not be denied because of the hallucinated or misconstrued legal authorities in Plaintiff's Amended........