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Incident 1555: Reportedly AI-Assisted Boies Schiller Brief in Bixler v. Church of Scientology Allegedly Contained Material Citation Errors and a Nonexistent Case

Description: Boies Schiller Flexner filed a respondents' brief in Bixler v. Church of Scientology International that was reportedly prepared with AI assistance and allegedly contained material citation errors. Opposing counsel reportedly identified mischaracterized and mistitled authorities, including one nonexistent case. Partner John Kucera accepted responsibility for failing to verify the citations and sought to replace the brief; the court denied that request and later considered monetary sanctions.
Editor Notes: Timeline notes: The incident date is 07/30/2025; the incident record was created on 06/25/2026. For supporting documentation, please refer to the official appellate docket here: https://appellatecases.courtinfo.ca.gov/search/case/dockets.cfm?dist=2&doc_id=3105460&doc_no=B339009&request_token=NiIwLSEnTkw2W1BdSCM9XElIQFQ6USxXICBORzpRICAgCg%3D%3D. In particular, see the docket entry dated 02/19/2026.

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Alleged: Generative AI developers developed an AI system deployed by Lawyers , Law firms , John Kucera and Boies Schiller Flexner LLP, which harmed Plaintiffs in Bixler v. Church of Scientology International , Judicial integrity , Epistemic integrity , Clients of lawyers , Church of Scientology International , Church of Scientology Celebrity Centre International and California Court of Appeal, Second Appellate District.
Alleged implicated AI systems: Boies Schiller Flexner AI-assisted legal drafting workflow and AI-assisted legal drafting systems

Incident Stats

Incident ID
1555
Report Count
1
Incident Date
2025-07-30
Editors
Daniel Atherton

Incident Reports

Reports Timeline

Incident OccurrenceCitation errors and hallucinated case turn up in Boies Schiller brief in 'artificial-intelligence debacle'
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Citation errors and hallucinated case turn up in Boies Schiller brief in 'artificial-intelligence debacle'

Citation errors and hallucinated case turn up in Boies Schiller brief in 'artificial-intelligence debacle'

abajournal.com

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Citation errors and hallucinated case turn up in Boies Schiller brief in 'artificial-intelligence debacle'
abajournal.com · 2025

A partner at Boies Schiller Flexner is seeking to file a corrected brief in litigation against the Church of Scientology after taking responsibility for "material citation errors" that it contained.

In a Sept. 19 declaration, partner John K…

Variants

A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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