On May 26, 2023, Judge Castel of the Southern District of New York, in the case Mata v. Avianca (No. 22-cv-01461) entered an Order to Show Cause asking why an attorney should not be sanctioned and referred to the Attorney Grievance Committee. The judge’s order stems from the filing of an affirmation and memorandum of law by a pair of attorneys which cited to several nonexistent cases, complete with nonexistent quotes and holdings which seem to have been generated by ChatGPT, a large language model AI system created by OpenAI.

While the facts of Mata may seem extreme, it is likely a harbinger of the broader minefield of legal and ethical issues that are rapidly emerging from the recent explosion of capabilities of generative AI systems and their adoption and use within the practice of law.