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Incident 623: Google Bard Allegedly Generated Fake Legal Citations in Michael Cohen Case

Responded
Description: Michael Cohen, former lawyer for Donald Trump, claims to have used Google Bard, an AI chatbot, to generate legal case citations. These false citations were unknowingly included in a court motion by Cohen's attorney, David M. Schwartz. The AI's misuse highlights emerging risks in legal technology, as AI-generated content increasingly infiltrates professional domains.

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Entities

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Alleged: Google Bard and Google developed an AI system deployed by Michael Cohen and David M. Schwartz, which harmed Michael Cohen and David M. Schwartz.

Incident Stats

Incident ID
623
Report Count
12
Incident Date
2023-12-12
Editors
Applied Taxonomies
MIT

MIT Taxonomy Classifications

Machine-Classified
Taxonomy Details

Risk Subdomain

A further 23 subdomains create an accessible and understandable classification of hazards and harms associated with AI
 

3.1. False or misleading information

Risk Domain

The Domain Taxonomy of AI Risks classifies risks into seven AI risk domains: (1) Discrimination & toxicity, (2) Privacy & security, (3) Misinformation, (4) Malicious actors & misuse, (5) Human-computer interaction, (6) Socioeconomic & environmental harms, and (7) AI system safety, failures & limitations.
 
  1. Misinformation

Entity

Which, if any, entity is presented as the main cause of the risk
 

Human

Timing

The stage in the AI lifecycle at which the risk is presented as occurring
 

Post-deployment

Intent

Whether the risk is presented as occurring as an expected or unexpected outcome from pursuing a goal
 

Intentional

Incident Reports

Reports Timeline

Incident OccurrenceMichael Cohen lawyer's citing of fictional case raises ChatGPT suspicions+8
Former Trump ‘fixer’ Michael Cohen admits using Google Bard to cite bogus court cases
AI models frequently ‘hallucinate’ on legal queries, study findsJudge Won’t Punish Michael Cohen for Relying on Artificial Intelligence - Response
Michael Cohen lawyer's citing of fictional case raises ChatGPT suspicions

Michael Cohen lawyer's citing of fictional case raises ChatGPT suspicions

newsweek.com

Former Trump ‘fixer’ Michael Cohen admits using Google Bard to cite bogus court cases

Former Trump ‘fixer’ Michael Cohen admits using Google Bard to cite bogus court cases

ca.finance.yahoo.com

Michael Cohen used AI tool to generate bogus cases in court filing

Michael Cohen used AI tool to generate bogus cases in court filing

independent.co.uk

Michael Cohen used fake cases created by AI in bid to end his probation

Michael Cohen used fake cases created by AI in bid to end his probation

washingtonpost.com

Michael Cohen used Google's AI to research legal cases to cite in his appeal. The AI hallucinated them.

Michael Cohen used Google's AI to research legal cases to cite in his appeal. The AI hallucinated them.

businessinsider.com

Michael Cohen admits fake cases in early release bid came from Google AI program

Michael Cohen admits fake cases in early release bid came from Google AI program

abcnews.go.com

Ex-Trump fixer Michael Cohen says AI created fake cases in court filing

Ex-Trump fixer Michael Cohen says AI created fake cases in court filing

reuters.com

Former Trump lawyer Michael Cohen accidentally cited fake court cases generated by AI

Former Trump lawyer Michael Cohen accidentally cited fake court cases generated by AI

theverge.com

Donald Trump's Ex-Lawyer Michael Cohen Cites Fake Cases Imagined By Google's AI Bard; Thought It Was 'Super-Charged Search Engine'

Donald Trump's Ex-Lawyer Michael Cohen Cites Fake Cases Imagined By Google's AI Bard; Thought It Was 'Super-Charged Search Engine'

english.jagran.com

Trump’s former lawyer blames AI for fake citations in legal documents

Trump’s former lawyer blames AI for fake citations in legal documents

cointelegraph.com

AI models frequently ‘hallucinate’ on legal queries, study finds

AI models frequently ‘hallucinate’ on legal queries, study finds

thehill.com

Judge Won’t Punish Michael Cohen for Relying on Artificial Intelligence

Judge Won’t Punish Michael Cohen for Relying on Artificial Intelligence

nytimes.com

Michael Cohen lawyer's citing of fictional case raises ChatGPT suspicions
newsweek.com · 2023

A lawyer for Michael Cohen, the one time fixer and attorney for Donald Trump, has been accused of citing non-existent court cases in legal filings after using artificial intelligence program ChatGPT for research.

David M. Schwartz, who is r…

Former Trump ‘fixer’ Michael Cohen admits using Google Bard to cite bogus court cases
ca.finance.yahoo.com · 2023

Donald Trump's former "fixer," Michael Cohen, used Google Bard to cite made-up legal cases that ended up in a federal court. The New York Times reported Friday that Cohen admitted in unsealed court papers that he passed on documents referen…

Michael Cohen used AI tool to generate bogus cases in court filing
independent.co.uk · 2023

Michael Cohen, Donald Trump’s one-time lawyer and “fixer” used Google Bard, the artificial intelligence program, to provide his lawyer with fictitious legal citations, according to newly unsealed court papers.

The fake citations were then i…

Michael Cohen used fake cases created by AI in bid to end his probation
washingtonpost.com · 2023

Michael Cohen, a former fixer and lawyer for former president Donald Trump, said in a new court filing that he unknowingly gave his attorney bogus case citations after using artificial intelligence to create them as part of a legal bid to e…

Michael Cohen used Google's AI to research legal cases to cite in his appeal. The AI hallucinated them.
businessinsider.com · 2023

The latest victim of an AI screw-up? Donald Trump's former fixer Michael Cohen and his lawyer.

Cohen admitted in a sworn statement in a Manhattan federal court case that he used Google Bard, a generative AI chatbot similar to ChatGPT, to fi…

Michael Cohen admits fake cases in early release bid came from Google AI program
abcnews.go.com · 2023

Former President Donald Trump's onetime fixer Michael Cohen sent his attorney non-existent legal cases produced by the artificial intelligence program Google Bard as he sought to beef up his petition for early termination of his supervised …

Ex-Trump fixer Michael Cohen says AI created fake cases in court filing
reuters.com · 2023

Michael Cohen, Donald Trump's former fixer and lawyer, said in court papers unsealed on Friday that he mistakenly gave his attorney fake case citations generated by an artificial intelligence program that made their way into an official cou…

Former Trump lawyer Michael Cohen accidentally cited fake court cases generated by AI
theverge.com · 2023

Michael Cohen, the former lawyer for Donald Trump, admitted to citing fake, AI-generated court cases in a legal document that wound up in front of a federal judge, as reported earlier by The New York Times. A filing unsealed on Friday says …

Donald Trump's Ex-Lawyer Michael Cohen Cites Fake Cases Imagined By Google's AI Bard; Thought It Was 'Super-Charged Search Engine'
english.jagran.com · 2023

Soon after news of lawyers using ChatGPT to supercharge legal research but ending up with a disaster gripped the media, Google Bard is emerging as a second option. In the latest move, Michael Cohen, the former lawyer of Donald Trump, had ac…

Trump’s former lawyer blames AI for fake citations in legal documents
cointelegraph.com · 2023

Michael Cohen, a former lawyer for Donald Trump, confessed to mistakenly giving his attorney incorrect case citations created by the artificial intelligence (AI) chatbot Google Bard.

In a recent court filing, Cohen, who is set to be a witne…

AI models frequently ‘hallucinate’ on legal queries, study finds
thehill.com · 2024

Generative artificial intelligence (AI) models frequently produce false legal information, with so-called "hallucinations" occurring between 69 percent to 88 percent of the time, according to a recent study.

Large language models (LLMs) ---…

Judge Won’t Punish Michael Cohen for Relying on Artificial Intelligence
nytimes.com · 2024
Benjamin Weiser post-incident response

A Manhattan judge on Wednesday declined to impose sanctions on Michael D. Cohen, the onetime fixer for former President Donald J. Trump, after he mistakenly gave his lawyer fake legal citations concocted by Google Bard, an artificial intell…

Variants

A "variant" is an incident that shares the same causative factors, produces similar harms, and involves the same intelligent systems as a known AI incident. Rather than index variants as entirely separate incidents, we list variations of incidents under the first similar incident submitted to the database. Unlike other submission types to the incident database, variants are not required to have reporting in evidence external to the Incident Database. Learn more from the research paper.

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