(DCNF)—Artificial intelligence continues to produce fake court citations as companies market their language models to law firms.
Generative AI hallucinations were listed in more than 2,000 court decisions since 2023, according to a public database created by legal researcher Damien Charlotin. At the same time, Google just promoted its legal AI tool as a “complement” to legal teams, according to an Axios interview released Tuesday.
“I view it as a complement, not a replacement,” Halimah DeLaine Prado, Google’s general counsel, told Axios. “The practice of law will always fundamentally rise and fall on the exercise of good judgment.”
DeLaine Prado added that AI already assists Google’s legal team with various tasks, such as contract redlining, e-discovery and litigation preparation, and she said these tools could make it easier for small law firms to compete with larger firms, according to Axios.
A spokesperson for Google’s Gemini Enterprise for Legal declined to comment before the time of publication.
“Last year saw, at first, an exponential rise in cases where people were caught hallucinating, but we have now reached a plateau,” Charlotin, a senior research fellow at HEC Paris, told the Daily Caller News Foundation about the findings of his AI hallucination research.
“[There are] several causes for this, amongst which [are] better tools and higher awareness,” Charlotin added. He explained that both frequency and severity of AI hallucinations have plateaued in the past year.
The data currently consists of 2,022 cases of AI-generated content, such as fake citations, used in legal decisions across the globe from April 2023 through Sept. 5 2026, according to Charlotin’s website. More than 1,300 were U.S. cases.
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Google’s AI models, specifically Gemini and Bard, were cited in a total of 10 cases, according to Charlotin’s data. ChatGPT was cited over 100 times.
Most cases resulted in a warning, with fewer than 160 cases resulting in disciplinary action, according to the data. Most fines for these incidents were between $1,000 and $5,000.
“[A]ll things otherwise equal, free LLMs [large language models], especially those that can’t search the Internet, hallucinate more as a baseline,” Charlotin told the DCNF. “Unfortunately, that’s also the kind of models self-represented litigants (the majority of cases in the database) tend to use.”
In one of the earliest cases in Charlotin’s data, two lawyers cited fake court cases in their legal brief that were generated by ChatGPT before being sanctioned by a New York federal judge.
“[T]he law firm of Levidow, Levidow & Oberman P.C. … abandoned their responsibilities when they submitted non-existent judicial opinions with fake quotes and citations created by the artificial intelligence tool ChatGPT,” the court stated in a June 2023 sanctions order.
Even after the court questioned whether the cases were real, the firm continued to defend them, according to the legal order.
Google launched Gemini Enterprise for Legal in August to perform legal tasks that the company said regular large language models (LLMs) cannot accomplish.
“Gemini Enterprise for Legal includes an open ecosystem that extends its capabilities with specialized [AI] agents like Deloitte Legal Assist, bringing deep legal experience to a platform with centralized governance and control,” Google Cloud said in a Sept. 5 X post promoting Gemini Enterprise.
The legal AI model provides “skills that enhance a firm’s own expertise, connections into the systems where matters actually live, agents that complete work rather than return suggestions, and an open ecosystem to extend all of its — with governance running underneath all four,” according to an Aug. 25 blog post from Thomas Kurian, CEO of Google Cloud.
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Starting the Day With a Scripture-Inspired Roast Helps Center Your Thoughts on Eternal Truths Amid Temporal Pressures
The world can seem chaotic, especially right after we wake up. Many believers start their mornings reaching for something familiar — a hot cup of coffee — yet end up settling for mediocre brews that do little more than deliver a caffeine jolt. The daily grind of life, with its endless distractions, news cycles, and responsibilities, can leave even the most faithful feeling spiritually parched alongside their physical fatigue. What if your morning ritual could do more than wake you up? What if it could ground you in truth, nourish your body with exceptional quality, and quietly advance a kingdom purpose at the same time?
That’s the promise — and the reality — behind Promised Grounds Coffee. This Christian-founded company doesn’t just roast beans; it approaches every step as an act of worship and discipleship. By selecting only the top 10% of specialty-grade beans, ethically sourced from dedicated farmers in Central and South America, and small-batch roasting them with reverence in Austin, Texas, Promised Grounds delivers what many describe as the best coffee available — never burnt, never bland, but rich with origin stories and layered flavors that honor God’s creation.
From the vibrant Psalm 27 Roast (a light, bright medium option) to the bold yet peaceful 2 Timothy 1:7 Decaf, each bag carries a Scripture verse that turns your daily pour into a gentle reminder of faith. And through their Ounce Per Ounce Promise, every ounce of coffee you enjoy provides an equal ounce of clean water to families in need via partnership with Filter of Hope — literally brewing hope for body and soul, one cup at a time.
The challenge for today’s Christians runs deeper than finding a decent cup. In an age of convenience-driven consumerism, it’s easy to support companies that dilute values or remain silent on matters of faith. Many believers want their everyday choices — from what they drink to how they spend — to reflect discipleship rather than just convenience. Promised Grounds solves this by weaving Christian excellence into the entire process: beans nurtured with prayerful stewardship by farming families, roasted as an offering rather than a commodity, and packaged with Bible verses to encourage a mindset of gratitude and purpose from the first sip. Reviewers consistently praise the smooth, rich profiles — whether enjoyed black in a drip maker, iced on a warm day, or shared in fellowship — noting how the quality stands toe-to-toe with premium secular brands while delivering something far more meaningful.
This integration of faith and flavor addresses a real need in Christian households and ministries. Busy parents, church leaders, and remote workers alike report that starting the day with a Scripture-inspired roast helps center their thoughts on eternal truths amid temporal pressures. The coffee’s exceptional character — bright citrus notes in lighter roasts or deep chocolate undertones in bolder ones — comes from meticulous selection and careful roasting that respects the bean’s natural gifts rather than masking them. It’s the kind of coffee that elevates a simple quiet time, fuels productive workdays, or sparks meaningful conversations when shared at Bible studies or outreach events. And because it’s ethically sourced with integrity, every purchase supports sustainable livelihoods for farmers who treat their crops like family harvests.
For those leading churches or small groups, the impact multiplies. Promised Grounds offers bundles and options perfect for hospitality ministries, turning ordinary coffee service into an opportunity to point people toward the living water of Christ. Imagine greeting visitors with a warm cup whose very bag carries God’s Word — a subtle yet powerful witness that aligns with the Great Commission. The company’s Texas roots and commitment to “brewing hope” resonate especially with believers who value American enterprise paired with global compassion.
Of course, quality alone isn’t enough if the experience feels out of reach. Promised Grounds keeps it accessible with practical perks like free shipping on orders over $40, sample sets for discovering favorites, and thoughtful add-ons such as faith-themed mugs. Whether you prefer whole beans for fresh grinding, grounds for convenience, or even bulk options for larger households and ministries, the result is consistently superior coffee that makes discipleship feel integrated rather than added on.
As you consider how to align even the smallest habits with your walk with God, Promised Grounds Coffee stands out as a refreshing solution. It tackles the dual problems of subpar daily sustenance and disconnected consumption by offering a product that genuinely excels in taste while advancing a mission of clean water, farmer dignity, and scriptural encouragement. Believers who make the switch often describe it as more than a beverage upgrade — it becomes part of their rhythm of gratitude, a daily invitation to remember that every good gift comes from above.
If you’re ready to transform your mornings (and perhaps your church gatherings) with coffee that honors both exceptional craftsmanship and Christian values, I encourage you to explore what Promised Grounds has to offer. One sip at a time, you’ll be nourishing your body, refreshing your spirit, and participating in something far greater — all while enjoying what truly is among the best coffee available.
