Westlaw CoCounsel Reportedly Generated False Legal Quotations in United States v. Farris

October 21, 2025

In a case that highlights the need for responsible AI governance, court-appointed attorney Steven N. Howe admitted using Westlaw CoCounsel to draft appellate briefs that reportedly included AI-generated false quotations and misleading descriptions of precedent. The filing disrupted Farris's appeal, leading the court to appoint new counsel and restart briefing, while Howe lost his compensation and faced possible disciplinary action.

The incident underscores the importance of ensuring trustworthy AI models like those used in Westlaw CoCounsel are properly governed and monitored for harm prevention. HISPI Project Cerebellum TAIM can help guardrails be put in place to prevent similar incidents in the future. Through contributors—JOIN US—to learn more about this issue and how to implement better AI governance practices.

Matched TAIM controls

Suggested mapping from embedding similarity (not a formal assessment). Browse all TAIM controls

Alleged deployer
steven-n.-howe, legal-professionals, law-firms
Alleged developer
thomson-reuters, large-language-model-developers, ai-research-tool-developers
Alleged harmed parties
united-states-court-of-appeals-for-the-sixth-circuit, legal-clients, judicial-integrity, john-c.-farris, epistemic-integrity

AI governance case studies

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Source

Data from the AI Incident Database (AIID). Cite this incident: https://incidentdatabase.ai/cite/1572

Data source

Incident data is from the AI Incident Database (AIID).

When citing the database as a whole, please use:

McGregor, S. (2021) Preventing Repeated Real World AI Failures by Cataloging Incidents: The AI Incident Database. In Proceedings of the Thirty-Third Annual Conference on Innovative Applications of Artificial Intelligence (IAAI-21). Virtual Conference.

Pre-print on arXiv · Database snapshots & citation guide

We use weekly snapshots of the AIID for stable reference. For the official suggested citation of a specific incident, use the “Cite this incident” link on each incident page.