A database that tracks AI hallucinations in court passed 2,246 cases this week. Damien Charlotin, a senior research fellow at HEC Paris, built it and keeps it current most days1. Lawyers filed 887 of those cases. Self-represented people filed 1,296.
Self-Represented Filers Account for 1,296 of 2,246 AI Hallucination Cases
Who filed each case in Damien Charlotin's global tracker of AI hallucinations in court, as of Oct. 31, 2026
Each cube stands for five cases; magenta cubes are self-represented filings, blue cubes are filings by lawyers, and gray cubes cover judges, experts and every other filer.
Source: Damien Charlotin [1]. Chart by Ryan Elliott Dennis.
The numbers behind this chart
| Item | Value |
|---|---|
| Self-represented filers | 1,296 |
| Lawyers | 887 |
| Judges, experts, others | 63 |
| Whole | 2,246, each cube 5 |
Read the easy way, this counts a profession behaving badly. A fine lands here. Another suspension lands there. Bar associations circulate warnings, and law blogs count the casualties.
That reading skips the larger group in the same database. Self-represented filers outnumber lawyers in Charlotin's count by nearly three to two1. Coverage of the crisis still centers on the lawyers. A sanctioned attorney has a bar number, a firm, and a name reporters can print.
Charlotin has watched the mix shift. He tracked a sharp rise in hallucination cases last year, then a plateau, as tools improved and lawyers grew wary4. Free, search-blind chatbots still hallucinate more than the paid ones law firms buy, he found.
"[A]ll things otherwise equal, free LLMs [large language models], especially those that can't search the Internet, hallucinate more as a baseline," Charlotin said4. That gap falls hardest on people stuck with the free kind.
Maritza Braswell sits as a federal magistrate judge in Colorado. She watched self-represented filings climb across her docket and ties the climb to AI use she sees firsthand. "I do correlate that to AI in part because I see AI use," she said2. Nationwide, the share of self-represented federal lawsuits rose from 11 percent in 2022 to 16.8 percent in 2025.
Self-Represented Federal Lawsuits Climb From 11% to 16.8% by 2025
Share of federal civil lawsuits filed by someone representing themselves, 2022 versus 2025
Source: MIT Technology Review [2]. Chart by Ryan Elliott Dennis.
The numbers behind this chart
| Item | Value |
|---|---|
| 2022 | 11% |
| 2025 | 16.8% |
AI widened access to the courts and left the odds unchanged. Joshua Levy, a researcher at the University of Southern California, studied 4.5 million federal civil cases filed from 2005 to 2026. Self-represented filers still lose far more often than filers with lawyers, AI tools included2. Clear writing explains only part of any case's outcome, his research found.
Levy worked with a co-author, Anand Shah at MIT. Together they tested 1,600 sampled court filings with Pangram, a tool built to flag AI-written text2.
Judge Allison Goddard sits on the federal bench in San Diego. She resists the access-to-justice framing. "I think hallucinations are a bad lawyer problem, not a bad AI tool problem," she said3. Courts run on public confidence, she argues, and that confidence rests on accurate orders every time.
Attorneys keep their licenses after a hallucination, whatever the fine. One Oregon dispute alone drew $110,000 in sanctions3. A self-represented filer risks the one claim they came to court to make.
Weigh who pays here. Legal aid groups turn away about half of the eligible people who ask for help. Ninety-two percent of poor Americans get too little help with a serious civil problem5. Those people turn to whatever chatbot sits open on their phone, then file.
Everlaw and its partners surveyed legal aid leaders this year. Eighty-eight percent said AI can already help close that gap, and 90 percent expected it to cut costs and serve more clients5. That optimism sits inside legal aid offices, far from the kitchen table where a self-represented filer drafts a brief alone.
Lawyers who hallucinate pay a fine and keep practicing. Vendors sell the same free tool to both sides and profit either way. The unrepresented filer carries the sharpest risk: one claim, filed alone, already struck by the judge who caught it.
The count in Charlotin's database settles the question his headlines keep avoiding. Most of the people fabricating case law in American courts represented themselves from the start. The next fight over AI and the courts belongs to them, the filers the lawyer-sanction stories leave out.
AI Lately's daily email, The Signal, follows exactly this kind of story. It tracks who AI moves, and who it leaves standing alone in front of a judge. Sign up, and read it each morning.
Sources
- Damien Charlotin, "AI Hallucination Cases Database," updated Oct. 31, 2026, https://www.damiencharlotin.com/hallucinations/
- Michelle Kim, "How courts are coping with a flood of AI-generated lawsuits," MIT Technology Review, June 4, 2026, https://www.technologyreview.com/2026/06/04/1138391/courts-coping-ai-lawsuits/
- Dan Levin, "AI is changing the legal system, but who's held accountable when it gets things wrong?" Straight Arrow News, Oct. 28, 2026, https://san.com/cc/ai-is-changing-the-legal-system-but-whos-held-accountable-when-it-gets-things-wrong/
- Dylan Kresak, "AI Faked Citations In More Than 2,000 Cases As Google Pitches Legal Model," Daily Caller News Foundation, Sept. 8, 2026, https://dailycallernewsfoundation.org/2026/09/08/ai-faked-citations-court-decisions-database-damien-charlotin/
- Andrew Braun, "AI and Technology Help Bridge Access to Justice," Pro Bono Institute, Feb. 6, 2026, https://www.probonoinst.org/2026/02/06/ai-and-technology-help-bridge-access-to-justice/