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This study benchmarks AI models' ability to detect fabricated legal citations, revealing significant limitations in current agentic frameworks despite improvements from GPT-5. The research highlights critical policy challenges regarding resource intensity for verification and the disadvantage faced by litigants without access to commercial databases. These findings underscore the urgent need for robust auditing tools before widespread deployment of AI in judicial proceedings.
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Who Checks the Citations? Benchmarking Legal Hallucination Detection

arXiv2 min read

arXiv:2606.21155v2 Announce Type: replace Abstract: Attorneys, judges, and pro se filers increasingly use AI to draft legal documents, yet these tools frequently fabricate citations. Despite predictions that newer models would hallucinate less or that court sanctions would deter negligent filers, we found over 1,000 filings containing fabricated citations---with this number growing year-over-year. This study evaluates whether AI-based systems can mitigate these errors by automatically detecting hallucinations. We propose a taxonomy of legal citation hallucinations grounded in actual court filings and introduce a dataset of 1,300 brief excerpts containing injected errors. Benchmarking five models in agentic and non-agentic settings as well as Claude Code reveals that while the latest iterations perform better---GPT-5 achieves 84.4% recall and a 55.0% F1 score in an agentic framework---all models struggle with subtle error categories. Agentic verification remains resource-intensive, with GPT-5 averaging 15.3 steps per excerpt. Furthermore, restricted information access limits the efficacy of even the best agents. This gap creates policy concerns, as it disadvantages both AI systems and litigants who lack subscriptions to commercial legal databases. Together, our dataset, tools, and policy recommendations provide a foundation for building and auditing reliable legal citation checking tools.

Title:Who Checks the Citations? Benchmarking Legal Hallucination Detection

Abstract:Attorneys, judges, and pro se filers increasingly use AI to draft legal documents, yet these tools frequently fabricate citations. Despite predictions that newer models would hallucinate less or that court sanctions would deter negligent filers, we found over 1,000 filings containing fabricated citations---with this number growing year-over-year. This study evaluates whether AI-based systems can mitigate these errors by automatically detecting hallucinations. We propose a taxonomy of legal citation hallucinations grounded in actual court filings and introduce a dataset of 1,300 brief excerpts containing injected errors. Benchmarking five models in agentic and non-agentic settings as well as Claude Code reveals that while the latest iterations perform better---GPT-5 achieves 84.4% recall and a 55.0% F1 score in an agentic framework---all models struggle with subtle error categories. Agentic verification remains resource-intensive, with GPT-5 averaging 15.3 steps per excerpt. Furthermore, restricted information access limits the efficacy of even the best agents. This gap creates policy concerns, as it disadvantages both AI systems and litigants who lack subscriptions to commercial legal databases. Together, our dataset, tools, and policy recommendations provide a foundation for building and auditing reliable legal citation checking tools.

Computation and Language (cs.CL)

arXiv:2606.21155 [cs.CL]

(or arXiv:2606.21155v2 [cs.CL] for this version)

https://doi.org/10.48550/arXiv.2606.21155 Focus to learn more arXiv-issued DOI via DataCite

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Full text under the publisher's open licence · 287 words

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