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NCOSE Lawyers Got Caught Citing Fake Cases. Their Corrected Brief Had More Fake Cases.

Failures

from the maybe-don't-trust-them? dept

Tue, Jun 30th 2026 05:34am -

Mike Masnick

The folks at the National Center on Sexual Exploitation (NCOSE) have spent decades demonizing technology (and speech) they don’t understand, so it seems particularly ironic that they’re now getting benchslapped for allowing AI hallucinated citations in legal filings.

First, some background: NCOSE has gone through a few different branding phases, but for a long while were known as "Morality in Media," an extraordinarily prudish and busybodyish entity that went around scolding retailers for offering magazines that showed models on the cover for being too sexy.

When they renamed themselves to NCOSE and started focusing on the internet (including the laughably false claim that any porn is a health issue and, now, that it’s a national security issue), they jumped on the anti-encryption and anti-Section 230 bandwagons, and politicians (including many Democratic ones who should have known better) quickly embraced the group under the false pretense that they actually were interested in ending sexual exploitation, rather than locking down the internet, and blocking any speech that acknowledges LGBTQ+ people exist.

Suffice it to say, the group is a far right, anti-sex, anti-speech, and anti-internet group, and it’s ridiculous that any politician supports them.

And now we can add to the list that their lawyers apparently can’t make it through a filing without fabricating citations — and then doubling down when caught. This came out in a convoluted case, in which NCOSE lawyers sued some Nevada brothels for supposedly exploiting women who chose to work there. It is possible that something bad happened in those places, but NCOSE apparently did themselves no favors by hiring a local lawyer whose AI-assisted work they were supposed to review — and then didn’t. Even worse, when the other side called out the hallucinated citations, NCOSE’s lawyers tried to attack the defendant and play down the hallucinations… in a filing with more hallucinated citations:

Let’s have Judge Andrew Gordon explain the basics:

Her briefs contained AI hallucinations. Despite Bistro pointing out these errors in its opposition, JD2 did not withdraw or correct her motion and her reply brief also contained misquotes. Bistro then filed a notice identifying the reply’s misquotes. About a month later, JD2 filed multiple errata, an amended motion for reconsideration, and an amended reply that purported to correct these errors, but the amended motion still contained AI hallucinations.

The order also suggests that NCOSE and the local lawyer they hired engaged in an awful lot of finger pointing and blame passing rather than, you know, doing actual lawyering. And then, once they were on notice of falsified filings, they… didn’t fix them. Indeed, NCOSE’s lawyers continued to rely on a hallucinated citation.

And thus, the defendants win their motion for sanctions, striking the falsified filings from the document, and denying the original request to reconsider an earlier ruling dismissing NCOSE’s exaggerated claims. The court notes that while it was the local lawyer who used the AI (and eventually admitted to doing so), the real problem is with NCOSE’s lawyers:

I have read Guinasso’s affidavit about the serious life events he was experiencing during the time frame of these violations, and I am sorry for his losses and the strain that must have put him under. But, as he acknowledges, that does not excuse the over-reliance on artificial intelligence without a human cite-checking the papers. I credit him for accepting responsibility and implementing procedures that hopefully preclude repeating this incident.

Although JD2’s motion and Guinasso’s declaration request that any sanctions fall solely on Guinasso, that is not appropriate here. There were six NCOSE attorneys on this case at the time. Additionally, the evidence before me shows that the NCOSE attorneys had some responsibility for cite checking. Although the errors may have begun with Guinasso, both Guinasso and Hirsch state that the NCOSE attorneys were supposed to double-check his citations. Moreover, Bistro’s opposition to the original motion for reconsideration should have put all attorneys on notice that there was an AI hallucination problem. Bistro devoted considerable space in its opposition to pointing out those errors, including that cases did not stand for the proposition cited, that quotations did not exist as cited, and...