Lawyers Caught Misusing AI Fuel Emerging Legal Education Sector

Bloomberg Law [no paywall]: “When a federal judge asked California solo practitioner William Becker Jr. to explain why a motion seemed to be riddled with AI-hallucinated citations, he knew what he needed to do. Becker, representing a defendant in a case involving former NFL punter Chris Kluwe, informed the judge that he’d taken “affirmative steps” to learn about professional responsibility issues around the use and misuse of AI, and that he attended a continuing legal education class on AI ethics for lawyers, promising to take another class soon. “I take the Court’s admonitions seriously,” said Becker in his Oct. 29 declaration. “I found it highly instructive and am integrating its guidance into my practice.” State bar and law firm leaders say attorneys such as Becker, and the growing number who have gotten into trouble for misusing AI like him, need to take greater responsibility for their AI use, and specifically when using generative AI programs like ChatGPT. Legal industry veterans are developing a broad range of AI-focused educational programs to help lawyers avoid embarrassing pitfalls and more effectively harness transformative tech that’s already streamlining lawyer workflows. “Lawyers are seeking more guidance, and we haven’t been giving them enough,” said Judge Xavier Rodriguez of the US District Court for the District of West Texas. “State bars are now recognizing that we need to do a better job,” said Rodriguez, who’s also a CLE instructor. After OpenAI introduced a more advanced iteration of ChatGPT in November 2022, the rise in misuse of generative AI chatbots in legal filings was modest and gradual from 2023 to 2024, according to a Bloomberg Law analysis. But with litigants’ use of the technology becoming increasingly common, instances of litigants’ misuse exploded in 2025, from 31 in the first quarter to 167 in the third. AI-focused CLE course offerings are proliferating, as pro se litigants, solo practitioners, small-firm lawyers, and “Big Law” attorneys increasingly face consequences for presenting courts with hallucinated, GenAI-devised citations and non-existent cases. Although tech advocates say CLE is a belated fix, it comes as scores of federal judges have issued standing orders and sanction orders meant to govern and guide AI use, according to BLaw data…”

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