NEW YORK, Nov 20 (Reuters) – One of the largest law firms to face scrutiny over its lawyers’ use of artificial intelligence avoided sanctions in a federal bankruptcy case on Thursday, but a judge reprimanded its attorney for submitting court filings with inaccurate and non-existent AI-generated citations.

The decision sparing sanctions against law firm Gordon Rees Scully Mansukhani is the latest to address so-called “hallucinations” generated by AI that have appeared in a growing number of court filings, and even two court decisions.

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U.S. Bankruptcy Judge Christopher Hawkins in Montgomery, Alabama, in an order, opens new tab said that Gordon Rees “took reasonable steps” to address the risk associated with using generative AI for legal work and declined to sanction the 1,800-lawyer firm.Gordon Rees already paid over $55,000 in attorneys’ fees related to the faulty filings to other parties in the hospital bankruptcy case, and it expanded its internal AI guidelines to include a new “cite checking” policy in response to his earlier order asking the firm to explain why it should not be sanctioned, Hawkins said.

The judge directed Gordon Rees to share a copy of his order and its policies with each lawyer at the firm and certify its compliance. A spokesperson for the San Francisco-founded firm did not immediately respond to a request for comment.

Hawkins formally reprimanded the Gordon Rees attorney responsible for the AI-generated errors, which appeared in filings on behalf of its now-former client Progressive Perfusion, a creditor in the bankruptcy case.

The attorney, Cassie Preston, had described struggling with serious personal events at the time of the filing, the judge said, but her conduct nevertheless “constituted an abuse of the bankruptcy process.”

Preston is no longer working at Gordon Rees, according to her profile on LinkedIn. She did not immediately respond to a request for comment.

Joel Connally, a lawyer at Strength & Connally who now represents Progressive, did not immediately respond to a request for comment.

The Chapter 11 bankruptcy case in the Middle District of Alabama was filed by Jackson Hospital & Clinic earlier this year.

Lawyers in an increasing number of cases across the country have faced sanctions after using AI for researching or drafting court documents and failing to verify the accuracy of their submissions.

Reporting by Sara Merken in New York

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Sara Merken reports on the business of law, including legal innovation and law firms in New York and nationally.