AI hallucinations in the facts section are a growing threat to litigators. By Jacqueline Schafer Aug 24, 2026 By now, every litigator has heard the warnings about the costly sanctions (in multiple cases, exceeding $100,000) if a pleading contains AI-hallucinated caselaw. Most litigators using generative AI when writing their briefs are aware of the risk of fabricated case citations and the many other ways generative AI can corrupt citations to legal authorities. What's getting far less attention is a quieter, arguably more dangerous problem: the growing prevalence of sanctions for AI-hallucinated fact cites. These are citations to the record, exhibits, depositions, emails, and any other factual discovery that either don't say what the brief claims or don't exist at all. Both fabricated case law and fake fact cites are hard to catch on your own when a brief contains hundreds of citations, but fact cites are arguably the trickier of the two. A fabricated case at least lives somewhere checkable by anyone at the firm who has access to a legal research repository; a fake fact cite hides inside your own repository of factual evidence that is not always accessible by the people working on the document as the brief gets closer to filing. Clearbrief is the only platform that systematically checks citations to both facts and law and displays the sources for your review as required by Rule 11 and new explicit court and bar rules in Florida, New, York, California, and many other jurisdictions. * It flags fabricated case law automatically through its direct integration partnerships with LexisNexis and Fastcase vLex (Clio), and * It connects every factual assertion in your brief straight to the underlying exhibit, deposition, or discovery document itself thanks to its integrations with Relativity, iManage, Netdocs, Reveal, Clio, MyCase 8AM, Sharepoint, Box, and many more. Sanctions cases for fake or misleading citations to factual evidence are increasing. As more lawyers have started using generative AI not only for legal research drafting but for other sections of their briefs and motions, hallucinated factual evidence has made its way into more pleadings. A database that tracks AI hallucinations in court pleadings has flagged dozens of sanctions cases in 2026 where fake facts were at issue. To highlight just a few: In a landmark "hallucinated facts" case in early 2026, the judge noted that courts across the country had largely dealt with citations to non-existent legal authority - but "this case is different, as it appears that AI was used not to hallucinate the law, but to hallucinate the facts." * The declaration contained multiple fabricated quotations presented to the court along with manufactured citations to deposition transcripts, as if they came from sworn testimony. It also grossly mischaracterized testimony and other facts in the record. The plaintiff admitted he used generative AI to draft at least a portion of his declaration and admitted he did not review it prior to signing, despite declaring under penalty of perjury that the content was true and correct. Sanctions totaled $5,000 ($4,000 against counsel and $1,000 against the litigant) and counsel was ordered to attend a CLE course. * In March 2026, the Court of Appeals for the 6th Circuit sanctioned a firm for fake factual citations to the Complaint and Appellees' brief, as well as hallucinated caselaw and misrepresented quotations ($30,000, adverse costs, & potential disciplinary proceedings). In addition to fake citations to a complaint and opposing counsel's brief, Clearbrief has seen: * Experts citing nonexistent articles: In In re Soc. Media Adolescent Addiction/Pers. Inj. Prods. Liab. Litig., No. 4:22-md-03047-YGR (N.D. Cal. Feb. 17, 2026), an expert admitted academic articles in his report don't exist, attributed to an AI citation tool. * Fabricated deposition quotes: * In Kennon v. Ashley, No. 24-4034-JWB (D. Kan. Feb. 18, 2026), counsel quoted nine deposition passages that don't appear on the cited transcript pages. Rule 11 show-cause order. * In Blazy v. Dep't of State, CBCA Nos. 7992, 7993 (Feb. 24, 2026), four deposition excerpts didn't appear on cited pages. Appellant admitted they were "constructed." Check out this short clip showing how Clearbrief "hooks up" your citations to facts automatically thanks to its integrations with Relativity, iManage, Netdocs, Clio, and more. New regulations mean that partners and anyone signing a pleading are personally responsible for verifying cited facts with their own eyes. In just the past few months, multiple jurisdictions have moved from guidance to hard rules: * Florida's Supreme Court now requires every attorney who signs a filing to personally represent that "the legal authorities identified exist and are accurately cited" - with sanctions authorized for violations. * New York's Part 161 codifies that anyone who uses AI in preparing a filing must independently review all cited sources and certifies, by signing, that the paper "contains no fabricated or fictitious cases, statutes, or other material." * California's State Bar issued updated guidance making clear that "a lawyer's professional judgment cannot be delegated to AI and remains the lawyer's responsibility at all times." * The Ninth Circuit's recent disciplinary order went further still, holding that an attorney's signature is a personal attestation that they read every cited authority with their own eyes - a duty that "cannot be delegated, disclaimed, or excused" by AI tools or subordinate drafters. The court called one attorney's admission that his team didn't "normally vet citations used by the Brief Writer" an "extraordinary confession." Put simply: courts are done accepting "the AI got it wrong" as a defense, for facts or for law. How Clearbrief closes the fact cite gap. Most cite-checking tools - and most habits built around them - focus on legal authority. Clearbrief was built to catch fabricated facts with the same rigor: * Smart Linking of Fact Cites: Automatically connects and displays every factual assertion in your brief to the specific page of the underlying exhibit, deposition, or discovery document it's supposed to support. That means anyone working on the brief can easily view the source as they read the hyperlinked Word document, satisfying their ethical requirements. * Semantic Scoring: Clearbrief's patented technology measures how closely your sentence actually maps to the language on the cited page, flagging anything with a middling or low score before a judge ever sees it. It doesn't just tell you a citation exists; it tells you whether it says what you claim it says. * Globally Add Fact Cites, now filterable by document type: If you drafted a facts section with an LLM and need pincites added to the factual evidence, you can select that entire section of text and Clearbrief will suggest and insert a citation after each sentence. You can also choose exactly which file types to pull suggestions from - say, emails and exhibits, but not a party's own brief. * Build a Cite-check Report for an audit trail: When you run Clearbrief's Analyzer, you can document you did it with a Cite-Check Report that can be shared with any other attorneys signing the brief. * Opposing-brief analysis: Convert a PDF from opposing counsel into an analyzable Word document and run the same fact- and case-verification diagnostic on their filing that you'd run on your own - closing the "we didn't catch it either" exposure courts are now penalizing. And because Clearbrief's Analyzer runs on deterministic technology rather than generative AI, it cannot itself hallucinate a red flag - it can only tell you, accurately, what is and isn't supported by evidence. Common mistakes that let fake fact cites through. Treating fact-checking as less important once the caselaw looks clean. A brief with airtight legal authority and fabricated facts is just as vulnerable to sanctions - arguably more so, since fact fabrication often reads as closer to intentional misrepresentation than a formatting error. Assuming "the junior attorneys will check the facts." Often, only the junior lawyers on the team know how to access and pull up the underlying factual evidence from repositories like Relativity. Without a systematic way to let others on the team quickly double check work product before filing, any facts section is at risk of containing mistakes that the court will sanction you and your clients for. Skipping verifying the factual evidence when time is short. Courts have made clear that time pressure isn't a defense. The Ninth Circuit's order singled out exactly this excuse in referring an attorney for discipline. Not checking opposing counsel's filings with the same scrutiny. As the recent wave of shared-sanction cases shows, "we didn't write it" is no longer a shield against "we didn't catch it." Conclusion: Fact cites can make or break your case as well as your reputation. Check them systematically. The rules have caught up to the risk. Florida, New York, California, and the Ninth Circuit have all made clear in the past few months that signing a filing means personally standing behind every cited source, not just cited cases. The fix is an operations matter. Litigation teams need to build a fact-cite verification step into the firm's filing workflow the same way you've already built in case-law verification. Tools like Clearbrief that connect every factual assertion directly to its underlying source, score how well it actually holds up, and generate an audit trail as you go turn that requirement from a burden into a quick process before you hit file. Want to learn more about putting a cite-checking Ops policy in place? Email Clearbrief at hello@clearbrief to get a full demo of Clearbrief, and check out its CEO's blog post on how to create a operations policy on checking both facts and law with Clearbrief.

NetDocuments adds Tabular Review and automatic extraction of Legal Authorities to its platform. August 20, 2026 The document management company NetDocuments today announced two additions to its platform's AI capabilities. One, Tabular Review, is a tool that lets users analyze collections of documents in a structured table. The other, Legal Authorities, automatically extracts case citations from documents as they are saved to the platform and links them to the full case text on CourtListener. The company is unveiling the new capabilities ahead of ILTACON 2026, which begins Sunday in Nashville, Tenn. Tabular Review. Tabular Review is a feature that converts a set of documents into a structured table for tasks such as due diligence, contract audits, regulatory reviews and compliance assessments. Using this tool, each document becomes a row in the table and user-defined questions become columns. The AI extracts and classifies information from every document in the set, with in-cell citations linking back to the source text in the original document. Users can define columns manually, specifying a name, data type and definition for each, or describe the review in plain language and have the AI generate suggested columns, which the user can then edit. During a media briefing last week, Scott Kelly, the company's vice president of product, demonstrated the feature by asking it to extract standard terms from a set of NDAs and licensing agreements. The tool produced a table populated by a set of columns such as payment terms. Kelly said the tool can process thousands of documents at a time with more than 100 columns. Hovering over a cell displays the passage supporting the extracted answer, and clicking opens a preview of the document with the relevant passages highlighted. Column configurations can be saved as templates for reuse, and results can be exported to Excel with citations included. Because the analysis is done within NetDocuments, the company says, documents remain subject to a firm's existing security controls, ethical walls, and policies governing AI use on client content. The feature is slated to roll out broadly over the next month or two, in both the company's classic interface and its newer redesigned user experience. "As AI capabilities continue to evolve, we are adding more powerful features like Tabular Review to support everyday workflows of legal professionals," Dan Hauck, chief product officer at NetDocuments, said in a statement announcing the release. Tabular Review joins the platform's existing AI capabilities, which include its Legal AI Assistant, an App Builder for AI-powered workflows, more than 40 prebuilt AI apps in its ndMAX Studio, and AI Profiling for automatic document classification and metadata extraction. Legal Authorities. The second announcement extends the Legal Context Graph, the layer of connected matter, document and expertise data that NetDocuments introduced earlier this year. Now, as documents are uploaded to the platform, it automatically extracts every legal citation they contain and feeds the citations into the graph, building a firm-wide, continuously updated map of the authorities referenced across the firm's documents and emails. From a document view, a lawyer can see an automatically generated table of authorities, navigate the document by clicking on individual cases, and follow a link to read each cited case on CourtListener, the free legal research database operated by the nonprofit Free Law Project. Each authority is also tied to the specific sentences that cite it, so a user can see where and how the firm has used a given case. During the briefing, Hauck said citations are one of several types of intelligence the company plans to derive from documents flowing into the platform. "Thousands of these kinds of documents get saved into NetDocuments every single day," he said, referring to briefs, memos and emails containing case citations. "Together, these capabilities represent what we've been building toward," Hauck said in the announcement. "A platform purpose-built for legal work, where the firm's institutional knowledge grows automatically, and every AI tool in the firm's stack, ours and our partners', gets smarter because of it." NetDocuments says its platform is used by more than 7,000 law firms, corporate legal departments and public sector organizations worldwide.

NetDocuments named No. 3265 on the 2026 Inc. 5000 List, the most prestigious ranking of America's fastest-growing private companies. August 11, 2026 NetDocuments recognized as one of the nation's most successful independent businesses for a fifth straight year, added to Honor Roll Lehi, Utah, August 11, 2026 - NetDocuments, the #1 trusted intelligent document management system for legal professionals today announced it has been named to the 2026 Inc. 5000 list, the annual ranking of the fastest-growing private companies in America, for the fifth consecutive year. This milestone earns NetDocuments(R) a place on the Inc. 5000 Honor Roll, a distinction reserved for companies that have appeared on the list five or more times, recognizing sustained, exceptional revenue growth. Since the Inc. 5000 was established in 1982, only 4% of companies have earned a place on the list five times, and less than 1% have achieved five consecutive appearances, placing NetDocuments among a select group of high-growth private companies. NetDocuments ranked No. 3,265 on the 2026 list, improving 614 positions from 2025 and 1,119 positions from its first appearance in 2022. "Our fifth consecutive year on the Inc. 5000 reflects both NetDocuments' continued growth and the strength of our customer relationships," said Josh Baxter, CEO of NetDocuments. "NetDocuments work alongside legal professionals to understand how their needs are evolving, enabling NetDocuments to build technology that helps firms operate more effectively, serve clients better and drive business growth. "As legal AI enters its next phase, context will be critical. With the industry's first Legal Context Graph, NetDocuments is uniquely positioned to connect firms' documents, knowledge and workflows - giving AI the rich legal context it needs to be useful, trusted and capable of helping legal professionals deliver higher-quality work. By staying close to our customers, we can help them turn their collective knowledge into better decisions and lasting business value." This year's Inc. 5000 recognizes a new class of companies redefining what growth looks like. From AI and advanced manufacturing to healthcare, consumer products, and professional services, these businesses are expanding their impact, creating jobs and proving that entrepreneurial ambition continues to fuel the U.S. economy. Among the 5,000 companies on the list, the median three-year revenue growth rate was 130%, and those companies have collectively added more than 627,208 jobs to the U.S. economy over the past three years. For the full Inc. 5000 list, honoree company profiles, and a searchable database by industry and location, please visit: www.inc.com/inc5000. "Every company on the Inc. 5000 has a story of perseverance, smart decision making, and a refusal to sit still," says Mike Hofman, editor-in-chief of Inc. "Their growth reflects more than strong financial performance - it reflects creativity, resilience, and the customer focus required to build companies that make a lasting impact. We congratulate all honorees on this significant achievement." Inc. will celebrate the honorees at the 2026 Inc. 5000 Conference & Gala, taking place October 14-16 in Dallas, Texas and the top 500 will be listed in the Fall issue of Inc. Magazine. Tickets are on sale now. Inc. 5000 List Methodology Companies on the 2026 Inc. 5000 are ranked according to percentage revenue growth from 2022 to 2025. To qualify, companies must have been founded and generating revenue by March 31, 2022. They must be U.S.-based, privately held, for-profit, and independent - not subsidiaries or divisions of other companies - as of December 31, 2025. (Since then, some on the list may have gone public or been acquired.) The minimum revenue required for 2022 is $100,000; the minimum for 2025 is $2 million. As always, Inc. reserves the right to decline applicants for subjective reasons. About NetDocuments NetDocuments, the #1 trusted cloud-native document management system (DMS) for 25+ years, delivers everything lawyers need to do their best work, including award-winning automation and AI to email management, search, collaboration, document bundling, advanced security, and more. With the industry's first legal context graph and a reimagined user experience built around it, NetDocuments(R) supercharges those experiences by connecting every matter, every project, and every case while respecting an organization's permissions and ethical walls. Supporting more than 7,000 law firms, corporate legal departments, and public sector organizations worldwide, the platform integrates with 150+ other technologies, including Microsoft 365, Claude by Anthropic, and Docusign, making it a core solution that meets users wherever they work. About Inc. Inc. is the leading media brand and playbook for the entrepreneurs and business leaders shaping its future. Through its journalism, Inc. aims to inform, educate, and elevate the profile of its community: the risk-takers, the innovators, and the ultra-driven go-getters who are creating the future of business. Inc. is published by Mansueto Ventures LLC, along with fellow leading business publication Fast Company. For more information, visit www.inc.com. (C) 2026 NetDocuments Software, Inc. All rights reserved. NetDocuments is the registered trademark of NetDocuments Software, Inc. in the United States and other jurisdictions. 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