AI False Citations “Hallucinations,” and Legal Risk: What Every Lawyer Needs to Know About Verification and Reliability

Ali Mohammed
Mark Underwood
Agnes Malatinszky
Ali Mohammed | JuristAI Legal Technology Group, Inc
Mark Underwood | JuristAI Legal Technology Group, Inc
Agnes Malatinszky | JuristAI Legal Technology Group, Inc

On-Demand: December 12, 2025

2 hour CLE

Tuition: $195.00
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Program Summary

This program will explore why current AI tools can sometimes prove unreliable for legal applications. Specifically, it will cover how AI can invent false case citations or statutory references, known as "hallucinations."

We will discuss why AI hallucinations occur and examine real-world examples from the AI Hallucination Cases Database, highlighting the risks they pose in legal practice. It will discuss when AI systems can be trusted and when human oversight remains essential.

Attendees will learn how JuristAI eliminates hallucinations from its outputs through rigorous validation methods. Attendees will also gain practical guidance on when and how to build a manual verification workflow, involving incorporating source-of-truth retrieval, citation checking, and human-in-the-loop review, especially for those not using automated hallucination detection tools.

Key topics to be discussed:

  • What is an AI hallucination?
  • Why do hallucinations occur?
  • When are users most at risk of hallucinations occurring?
  • What kind of AI produces hallucinations?
  • The categories of hallucinations (fake cites vs. pincites vs. fake quotes vs. irrelevance)
  • Consequences of submitting AI hallucinations in court (Rule 11)
  • The AI Hallucination Cases Database (https://www.damiencharlotin.com/hallucinations/)
  • When AI can be trusted and when it cannot
  • Is this problem unfixable?
  • Is it worth using AI if this is a risk?
  • Automated post-processing of AI output
  • Manual post-processing of AI outputs
  • How JuristAI pre-empts and removes hallucinations from our work outputs
  • How lawyers can build a manual verification workflow (source-of-truth retrieval, citation validation, and human-in-the-loop review) if they aren't using software hallucination detection

This course is co-sponsored with myLawCLE.

Closed-captioning available

Speakers

Ali Mohammed | JuristAI Legal Technology Group, Inc

Ali Mohammed is the CEO and a co-founder of JuristAI. He has always had a strong sense of justice and a passion for the law. Ali volunteered as an intern at a criminal justice firm during college. He went on to achieve a master’s in IT Management and became a solution architect.

 

Mark Underwood | JuristAI Legal Technology Group, Inc

Mark Underwood is the Co-Founder of JuristAI and creator of Lawvocate, an AI legal agent he trained that runs as a private GPT on OpenAI GPT-5 Thinking and is rolling out via the OpenAI API. A Fractional Chief Legal Officer and the Legal Community Leader at Startups.com, Mark advises founders and legal teams on AI governance, data, IP, and contract strategy. He has 37+ years of experience aligning product velocity with legal defensibility and is admitted to practice before the U.S. District Court for the Western District of Michigan.

Mark’s practical frameworks and commentary on law and emerging tech routinely reach thousands of practitioners and operators across the startup ecosystem.

 

Agnes Malatinszky | JuristAI Legal Technology Group, Inc

Agnes Malatinszky is a seasoned operator, investor, and leader who now builds and advises companies at the intersection of law, technology, and human centered design. A licensed attorney with a passion for practical problemsolving, she has helped scale organizations to millions of users and now focuses on creating entrepreneurial pathways and AI-powered tools that help people thrive.

Agenda

I. What is an AI hallucination? | 1:00pm – 1:10pm

II. Why do hallucinations occur? | 1:10pm – 1:20pm

III. When are users most at risk of hallucinations occurring? | 1:20pm – 1:30pm

IV. What kind of AI produces hallucinations? | 1:30pm – 1:40pm

V. The categories of hallucinations (fake cites vs. pincites vs. fake quotes vs. irrelevance) | 1:40pm – 1:50pm

VI. Consequences of submitting AI hallucinations in court (Rule 11) | 1:50pm – 1:55pm

VII. The AI Hallucination Cases Database (https://www.damiencharlotin.com/hallucinations/) | 1:55pm – 2:00pm

Break | 2:00pm – 2:10pm

VIII. When AI can be trusted and when it cannot | 2:10pm – 2:15pm

IX. Is this problem unfixable? | 2:15pm – 2:20pm

X. Is it worth using AI if this is a risk? | 2:20pm – 2:25pm

XI. Automated post-processing of AI output | 2:25pm – 2:30pm

XII. Manual post-processing of AI outputs | 2:30pm – 2:40pm

XIII. How JuristAI pre-empts and removes hallucinations from our work outputs | 2:40pm – 2:50pm

XIV. How lawyers can build a manual verification workflow (source of-truth retrieval, citation validation, and human-in-the-loop review) if they aren’t using software hallucination detection | 2:50pm – 3:10pm

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Pending CLE Approval
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 Technology in the Practice of Law

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hour(s)

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2.5 Technology Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Approved for CLE Credits
2 General

Hawaii

Approved for CLE Credits
2.4 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for Self-Study Credits
2 General

Indiana

Approved For On-Demand Credits
2 General

Kansas

Pending CLE Approval
2 Law Practice Management

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hour(s)

Maryland

No MCLE Required
2 CLE Hour(s)

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hour(s)

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for Self-Study Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Pending CLE Approval
2 General

North Carolina

Approved for Self-Study Credits
2 Technology

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Approved for Self-Study Credits
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Pending CLE Approval
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hour(s)

Tennessee

Approved for Self-Study Credits
2 General

Texas

Approved for CLE Credits
2 General

Utah

Pending CLE Approval
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Other (Office Management) Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for Self-Study Credits
2 Law Practice Management

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Approved for Self-Study Credits
2 General

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