A partner at Boies Schiller Flexner LLP has acknowledged the inclusion of erroneous, AI-generated citations in a legal brief submitted to a California appellate court. The brief was filed on behalf of women alleging harassment by the Church of Scientology after reporting sexual assaults committed by actor Danny Masterson. The attorney has requested the court to strike the flawed brief, expressing deep regret for the oversight and emphasizing that the errors should not adversely affect the clients’ case.
The issue came to light when the Church of Scientology identified multiple inaccuracies in the plaintiffs’ brief, suggesting that the errors bore hallmarks of AI-generated content. The church’s legal team highlighted instances where case citations were mischaracterized, referred to unrelated areas of law, or were entirely fabricated. For example, the brief cited a 1995 case, Adams v. Paul, to support an argument about conspiracy evidence, but the actual decision does not mention conspiracy at all. ([tonyortega.org](https://tonyortega.org/2025/09/21/scientology-catches-masterson-victim-attorneys-with-ai-fudged-citations-in-court-filing/?utm_source=openai))
This incident is part of a broader trend where legal professionals have faced challenges due to the uncritical use of AI tools in drafting court documents. Courts across the country are encountering filings that back arguments with nonexistent research generated by AI, prompting judges to impose fines and reprimands. ([washingtonpost.com](https://www.washingtonpost.com/nation/2025/06/03/attorneys-court-ai-hallucinations-judges/?utm_source=openai))
Boies Schiller Flexner LLP has previously faced scrutiny over its practices. In 2024, the firm was accused of coercing a client into perjury in a $300 million lawsuit, alleging that the firm engaged in a scheme to generate outsized legal fees. ([law.com](https://www.law.com/newyorklawjournal/2024/04/29/boies-schiller-dentons-accused-of-coercing-client-into-perjury-in-300m-suit/?utm_source=openai))
The recent AI-related error underscores the necessity for legal professionals to exercise caution when integrating artificial intelligence into their workflows. While AI can enhance efficiency, it also carries risks that require diligent oversight to maintain the integrity of legal proceedings.