Junior solicitor misled court with AI-generated legal citations
A junior solicitor at Pinsent Masons used artificial intelligence to draft two misleading emails to the High Court, citing legal provisions that do not exist. Insolvency and Companies Court Judge Mullen found the solicitor "almost entirely outsourced the thinking process to the program" and accepted the firm's self-referral to the Solicitors Regulation Authority as appropriate sanction.
The underlying matter was straightforward: a block transfer application to replace an administrator or liquidator moving to a new firm. These uncontested applications create particular risk because "there is no opposing party to point out an error in correspondence sent to the court", the judge said.
The AI hallucinations began immediately
On 30 March, the junior solicitor-referred to as Lawyer A-sent a letter citing a specific power in the Insolvency Rules 2016 and quoted what appeared to be the relevant provision. Judge Mullen checked the actual rule on legislation.gov.uk and in practitioner texts. It said nothing of the sort.
When asked to explain, the firm's 14 April response doubled down on the same false citation. The judge said he was "astonished" and found the explanation "impossible to accept".
The AI transcript revealed that the hallucinations "began almost immediately" in the 30 March letter. At one point, the AI itself warned the junior solicitor to check the provisions it had referenced. The solicitor did not.
Judge Mullen said: "Assuming that LA did not check the text of the rule, I consider this omission inexcusable."
Supervision failures at multiple levels
Senior associate Samantha Poulton supervised the junior solicitor but was unaware AI had been used for this application. She admitted failing to check the purported legal text before the 30 March letter was sent and failing to review the 14 April letter "with the necessary care required". She told the court she was "mortified".
Partner Steven Cottee approved the 30 March letter without checking its references. The judge found "a failure to supervise LA adequately" in relation to both letters.
Julie Herriott, Pinsent Masons' compliance officer, told the court that the firm did not name the junior solicitor publicly given their junior status and the firm's duty of care to an employee. The junior solicitor subsequently identified themselves to the regulator.
Lack of care, not dishonesty
Judge Mullen distinguished between carelessness and misconduct. He found the junior solicitor's conduct "very troubling" but said it "may well have resulted from a serious lack of care and of judgment" rather than dishonesty. The 14 April letter was not primarily an AI hallucination but rather a constructed rationale to defend the false citation-"an unjustifiable response and an opportunity to set the record straight became a further instance of misleading information being put before the court".
The judge said "admonishment is plainly insufficient" but referral for contempt proceedings would be "disproportionate". The SRA referral was "appropriate".
Pinsent Masons' compliance team outlined additional safeguards on AI use. Judge Mullen said he had "been left in no doubt that Pinsent Masons is taking this matter very seriously and is seeking to address the risks identified".
The firm covered extra costs for its former clients. Irwin Mitchell took over representation.
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