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The Heppner Problem

AI hallucinated citations are
getting attorneys sanctioned.

Heppner. Mata v. Avianca. Courts are sanctioning attorneys who file briefs with AI-generated cases that don't exist. The risk is real and growing.

The problem

Generative AI produces citations that look real — case names, reporters, page numbers, holdings. Some are entirely fabricated. The attorney who submits them faces Rule 11 sanctions, bar discipline, and malpractice liability.

How Marcella prevents it

Marcella retrieves from an indexed corpus of 10M+ opinions. Not in the index? Not in the output. Every citation passes a six-item Daubert attestation: real source, good law, overruled, distinguished, questioned, treatment history. All six answered before it reaches you.

Full analysis and incident database: heppner-problem.com

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