Michael Cohen’s AI Blunder: Unknowingly Citing Fake Google Bard-Generated Cases


Michael Cohen, former attorney and fixer for Donald Trump, admitted to unwittingly using artificial intelligence to fabricate legal citations in a court filing. This revelation surfaces amidst Cohen’s ongoing legal entanglements and his role as a potential witness against Trump in various legal proceedings.

Cohen disclosed in a recent court filing that he inadvertently submitted fictitious AI-generated legal citations to his lawyer, David Schwartz. These citations, generated by Google Bard, an AI chatbot, were then included in a motion submitted to a federal judge. Cohen, who served time in prison and is under supervised release, was using these citations to support a motion seeking early termination of his supervision. He mistakenly believed Google Bard to be a “super-charged search engine” and was unaware of its capabilities to generate non-existent legal cases​​​​.

This error was compounded by Schwartz’s failure to verify the citations. Schwartz assumed the cases were researched by another attorney, rather than Cohen, and did not contemplate that the cited cases were fictional. He acknowledged his responsibility for the submission and apologized for not personally checking the cases before presenting them to the court. This oversight raises questions about the due diligence practices in legal research and the reliance on AI tools​​​​.

While Cohen’s use of AI-generated citations was unintentional, it could potentially affect his credibility as a witness in ongoing legal cases against Trump. Cohen has testified against Trump in a New York civil case and is a key witness in an upcoming criminal case. The incident demonstrates the risks associated with emerging legal technologies and highlights the need for legal professionals to stay updated with these trends​​​​.


The incident involving Cohen and Google Bard sheds light on the increasing integration of AI in legal research. While AI tools can enhance research efficiency, they also pose risks, such as generating inaccurate or fictitious information. This situation underscores the importance of understanding the capabilities and limitations of AI in legal contexts. Lawyers and legal professionals must exercise caution and perform thorough verifications when using AI-generated content.

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