After confessing the firm submitted a post-trial motion citing a non-existent case helpfully supplied by ChatGPT, Goldberg Segalla cut ties with partner Danielle Malaty. Presumably, the firm hoped that would be the end of it.
But it seems that filing was just the amuse-bouche!
Upon realizing that Goldberg Segalla had inserted one fake citation, the plaintiffs wondered if it might be worth another quick glance at the docket. You know… because most lawyers enjoy chasing down important research instead of shrugging it off as good enough. A newly filed motion for sanctions in Jordan v. Chicago Housing Authority suggests the plaintiffs made the right move, outlining a systemic AI hallucination jamboree going well beyond an errant cite to the fictitious Mack v. Anderson case that started this ball rolling.
An Illinois jury awarded $24.1 million in this pediatric lead poisoning case where two children were left with irreversible brain damage after years of litigation. Rather than owning up to that outcome, the Chicago Housing Authority (CHA to its friends) and Goldberg Segalla opted to litigate the verdict into oblivion. It was the motion asking the judge to set aside the verdict that first uncovered that the Housing Authority’s legal arsenal might be cobbled together from AI-generated fan fiction.
Over the course of five days, having only the opportunity to review a slice of the docket, the plaintiffs discovered that when it comes to hallucinated research, not unlike Lay’s Potato Chips, betcha can’t cite just one.
Following the Court’s July 17, 2025 hearing which primarily focused on the CHA’s citation to the fabricated case of Mack v. Anderson, Plaintiffs’ counsel more closely reviewed additional pleadings filed by Goldberg Segalla on behalf of the CHA. Based on that additional review, it is evident that the CHA’s misrepresentations, false claims, and reliance on non-existent case law were not limited to a single citation – or even a single pleading. Rather, now unearthed is a pattern of repetitive and continuous misrepresentations to the Court. The misrepresentations identified to date are addressed below. When applied to the appropriate legal standard, it is clear that severe sanctions are warranted.
Digging into the pervasiveness of the illusion, plaintiffs checked out the Mid-Trial Offer of Proof that Goldberg Segalla showed to the expert witness and discovered “numerous faulty case citations, fabricated case quotations, and another non-existent case.” Here’s part of a table included with the sanctions motion:
It goes on like that for another page. And Mack v. Anderson shows up in there too.
The mistakes aren’t even limited to filings that matter! Way back in February, Goldberg Segalla filed a motion seeking an extension that plaintiffs weren’t even interested in contesting — which explains why no one bothered to give it much attention before now. Guess what happened?
And while the relief sought in the CHA’s Motion for Extension was neither extraordinary nor even contested, Plaintiffs have revisited that pleading too for a closer review. In a turn of ironic absurdity, the CHA’s Motion for Extension – seeking additional time to perform the requisite legal research to address the “significant legal questions” that the CHA anticipated in its Post-Trial Motion – is premised on faulty and invented legal authority.
Stop. No. Come on, people.
And, again, there are a couple more items in this table too.
Not even the post-trial motion that started this all escaped without further scrutiny with the plaintiffs identifying “extensive and far reaching misrepresentations – including outright falsehoods and problematic legal citations” beyond the Mack case. That table runs from page 16 to page 20 and includes alleged misrepresentations of cases and the factual record of the instant matter alike.
Most of the cases so far focus on hapless lawyers using AI for legal research and then never checking it (or, the new excuse of using another tech tool to “check” for mistakes that doesn’t end up working — possibly through operator error). But it can potentially create factual hallucinations too if someone shoves a transcript into the bot and asks it to pull information that it then mischaracterizes.
We just saw an Alabama federal court finally get tough on a hallucination case, kicking the Butler Snow lawyers off the case — over the objections of the client, no less! — while heaping considerable scorn on the most senior attorneys who tried to avoid responsibility by claiming that they’re too far above the mundane task of checking someone else’s work. Likewise in this case, the sanctions motion asserts that while the CHA threw Malaty under the CTA bus as the partner responsible for inserting the Mack case, the rest of the senior Goldberg Segalla team bear responsibility for checking the filings too.
This case is no longer about a single faulty citation that was the result of a “whoopsie” by a lawyer toying with new technology. This is now a case about successively filed pleadings that were fundamentally flawed based on the fact that they relied on non-existent or misrepresented caselaw. This is a case that also involves patently false misrepresentations about what actually happened at a trial of great public importance. This is a case where even in the face of inexcusable conduct, Goldberg Segalla and the CHA still press forward with defective pleadings in an attempt to throw out the jury’s verdicts.
As Judge Manasco wrote in the Butler Snow case of the AI hallucination sanctions to date, “If fines and public embarrassment were effective deterrents, there would not be so many cases to cite.” This judge in this case might soon join Judge Manasco’s sentiment.
(Full sanctions motion on the next page…)
Earlier: Partner Who Wrote About AI Ethics, Fired For Citing Fake AI Cases
Court Kicks Lawyers Off Case After Finding Fake AI Cases In Filings
Joe Patrice is a senior editor at Above the Law and co-host of Thinking Like A Lawyer. Feel free to email any tips, questions, or comments. Follow him on Twitter or Bluesky if you’re interested in law, politics, and a healthy dose of college sports news. Joe also serves as a Managing Director at RPN Executive Search.
The post Biglaw AI Apocalypse Brews As One Fake Case Turns Into Litany Of False Cites appeared first on Above the Law.