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The Volokh Conspiracy · September 14, 2026

Oklahoma Judge's Ruling Contained AI Hallucinations

LawPublic Administration
THE AI ANGLE
Generating hallucinated case citations used in a judicial order

An Oklahoma district court judge acknowledged using OpenAI's ChatGPT for legal research, which resulted in a drafted judicial order containing citations to two nonexistent cases. Following an inquiry by the Oklahoma State Bureau of Investigation, the state attorney general's office reviewed the findings and declined to pursue criminal claims. For law and public administration faculty, this case illustrates the procedural and ethical hazards of public officials relying on unverified generative AI outputs in official decision-making.

THE TEACHING ANGLE
This scenario offers an opportunity to examine judicial ethics and administrative accountability when public officials incorporate unverified generative AI tools into official legal research and drafting.

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