AI Law Security

On July 23, 2025, U.S. District Court Judge Julien Xavier Neals for the District of New Jersey directed the Clerk of Court to remove previously published court opinion and order¹ after attorneys for the defense identified “a series of errors in the Opinion—including three instances in which the outcomes of cases cited in the Opinion were misstated . . . and numerous instances in which quotes were mistakenly attributed to decisions that do not contain such quotes” were found in the court opinion.² In the text order of the court, Judge Neals noted that the “Opinion and Order were entered in error” and “[a] subsequent Opinion and Order will follow.”³

The background of In re CorMedix Securities Litigation involves the plaintiff, Mr. John C. Levon, bringing a class action lawsuit on behalf of individuals who held shares of CorMedix between October 16, 2019, and August 8, 2022, against the company. CorMedix is a biopharmaceutical company that “focused on the development and commercialization of products for the prevention and treatment of infectious disease.”⁴

The case centers around the plaintiff’s claim that CorMedix (the defendant) allegedly “made materially false and misleading statements and omissions concerning the [c]ompany’s ability to secure FDA approval”⁵ for DefenCath, one of CorMedix’s lead product candidates requiring FDA approval. The main thrust of the plaintiff’s claims centers around the defendant’s alleged violations under the Securities Act of 1933 and the Securities Exchange Act of 1934.

As of this article’s initial publication (originally published on Wednesday, July 23, 2025), the court record does not indicate why the removed court opinion contained misquotes and misstatements. As such, there is no evidence to suggest that AI hallucination played a role in creating court opinion errors at this time.

Nevertheless, this incident reaffirms the crucial role of attorneys in protecting the integrity of judicial proceedings, especially at a time when deepfakes and AI-hallucinated information threatens to undermine judicial process.

If additional information becomes available, this article will be updated.

References:

1. In re CorMedix Securities Litigation, No. 21-cv-14020 (D.N.J.), ECF No. 126, available via Court Listener <https://www.courtlistener.com/docket/60081508/in-re-cormedix-inc-securities-litigation/> ↩︎
2. In re CorMedix Securities Litigation, No. 21-cv-14020 (D.N.J.), ECF No. 123 (See Letter), available here. ↩︎
3. In re CorMedix Securities Litigation, No. 21-cv-14020 (D.N.J.), ECF No. 126 (“TEXT ORDER – The Court is in receipt of Defendants counsel’s letter dated July 22, 2025. (ECF No. 123 .) On June 30, 2025, the Court issued an Opinion and Order. (ECF Nos. 114, 115 .) That Opinion and Order were entered in error. Accordingly, the Court directs the Clerk of Court to remove the Opinion and Order at ECF Nos. 114 and 115 from the docket. A subsequent Opinion and Order will follow. So Ordered by Judge Julien Xavier Neals on 7/23/2025. (kd) (Entered: 07/23/2025)”) ↩︎
4. In re CorMedix Securities Litigation, No. 21-cv-14020 (D.N.J.), ECF No. 114 (See Opinion) at 2, available here. ↩︎
5. Id. ↩︎

On June 30, 2025, Judge Jeffrey A. Watkins of the Court of Appeals of Georgia issued his opinion for the case Nimat Shahid v Sufyan Esaam (Case number A25A0196) that was appealed by Ms. Nimat Shahid (Shahid) from a superior court (Georgia’s trial court) case involving a divorce.

Shahid argued that the superior court order was “void on its face,”¹ because it relied on two factitious cases. Mr. Sufyan Esaam’s attorney, Ms. Diana Lynch (Lynch), did not address directly to Shahid’s assertions, but Judge Watkins noted that Lynch relied on four cases in Lynch’s Appellee’s Brief where “two of which appear to be fictitious, possibly ‘hallucinations’ made up by generative-artificial intelligence (‘AI’), and the other two have nothing to do with the proposition stated in the Brief.” (footnotes removed)²

After reviewing the superior court’s order, Judge Watkins determined that “both of the cases cited in the order denying her petition to reopen [did] not exist.”³ As such, Judge Watkins continued,

Because the order denying her motion to set aside the divorce decree has a defect apparent on its face, we cannot conduct any meaningful appellate review of the merits of Wife’s argument that the court lacked jurisdiction over her person. Accordingly, we vacate the order and remand for further proceedings consistent with this opinion.
The superior court is specifically directed to hold a new hearing on Wife’s motion to set aside the divorce decree. (footnotes removed)⁴

In addition, Judge Watkin imposed a $2,500 frivolous motion penalty on Lynch, in part due to Lynch’s failure to address Shahid’s assertions that the superior court relied on two factitious cases and Lynch’s Appelle’s Brief containing “11 bogus case citations.”⁵

Significance: This may have been the first instance of a U.S. state judge unintentionally relying on factitious court cases to issue a court order.

References:

Shahid v. Esaam, A25A0196 (Ga. Ct. App. 2025). PDF of Judge Watkin’s available here.

Court of Appeals of Georgia Docket Search for case number A25A0196. Link: https://www.gaappeals.us/wp-content/themes/benjamin/docket/results_one_record.php?docr_case_num=A25A0196

1. Shahid v. Esaam, A25A0196 (Ga. Ct. App. 2025) at page 2. ↩︎
2. Id. at page 2-3. ↩︎
3. Id. at page 12. ↩︎
4. Id. at page 12-13. ↩︎
5. Id. at page 10. ↩︎