In re CorMedix Inc. Securities Litigation
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Conduct
Federal opinion contained fabricated quotations and nonexistent citations from a law-school intern's unauthorized ChatGPT use in chambers.
Consequence
Court withdrew the June 30 opinion and order on July 23 by text order, then reissued a corrected opinion seven weeks later.
Lesson
AI hallucination risk extends to the bench. Cite-check applies whether the source is a brief from counsel or an opinion from the court.
Verified May 7, 2026
- Citation
- In re CorMedix Inc. Securities Litigation, No. 2:21-cv-14020 (D.N.J. July 23, 2025) (Neals, J.) (Text Order withdrawing June 30, 2025 Opinion and Order)
- Decided
- July 23, 2025
Summary
In re CorMedix is the federal securities class action in which Judge Julien Xavier Neals issued an Opinion and Order on June 30, 2025 denying CorMedix Inc.'s motion to dismiss. Defense counsel later identified multiple errors in the opinion: a quotation attributed to Dang v. Amarin Corp. that does not appear in that case, a quotation attributed to In re Intelligroup that could not be verified, and a citation to a Southern District of New York case that legal databases could not locate. Defense counsel raised the errors in a July 22, 2025 letter to the court (ECF No. 123). On July 23, 2025, Judge Neals entered a Text Order stating that the prior Opinion and Order at ECF Nos. 114 and 115 "were entered in error," directed the Clerk to remove them from the docket, and indicated a subsequent opinion would follow. On October 20, 2025, in response to Senator Grassley's October 6 oversight inquiry, Judge Neals confirmed in a written letter that a "temporary assistant, specifically, a law school intern, used CHATGPT to perform legal research in connection with the CorMedix decision" without authorization, without disclosure, and contrary to chambers policy and law-school policy. Judge Neals committed to a written prohibition on generative AI use by clerks and interns going forward.
- AI tool:
- ChatGPT, used by a law-school intern (temporary assistant) in chambers without authorization or disclosure, per Judge Neals's October 20, 2025 letter to Senator Grassley
What sanction did the court impose?
June 30, 2025 Opinion and Order denying defendants' motion to dismiss were withdrawn from the docket on July 23, 2025 by Text Order. A reissued Opinion and Order denying the motion to dismiss were entered August 19, 2025 (ECF Nos. 127, 128). The court did not impose sanctions on any party. The reissued opinion reached the same outcome (denial) on a corrected legal record. The October 20, 2025 letter to Senator Grassley publicly confirmed that ChatGPT use by a law-school intern produced the errors.
Why does In re CorMedix Inc. Securities Litigation matter for law firms using AI?
In re CorMedix is the first widely-reported instance of a federal district court withdrawing an opinion after counsel identified errors consistent with generative AI hallucination patterns. Judge Julien Xavier Neals’s June 30, 2025 opinion denying CorMedix’s motion to dismiss in this securities-fraud class action contained at least three categories of error that defense counsel flagged in a July 22, 2025 letter (ECF No. 123): a quotation attributed to Dang v. Amarin Corp. that does not appear in that case, a quotation attributed to In re Intelligroup Securities Litigation that could not be verified, and a citation to a Southern District of New York case that does not exist in legal databases.
On July 23, 2025, Judge Neals entered a Text Order stating that the prior Opinion and Order “were entered in error” and directed the Clerk to remove ECF Nos. 114 and 115 from the docket. A reissued Opinion and Order entered on August 19, 2025 reached the same disposition (denying the motion to dismiss) on a corrected legal record. On October 20, 2025, in response to a written oversight inquiry from Senator Chuck Grassley dated October 6, 2025, Judge Neals confirmed publicly in a letter hosted on grassley.senate.gov that “a ‘temporary assistant,’ specifically, a law school intern, used CHATGPT to perform legal research in connection with the CorMedix decision.” The intern’s use was unauthorized, undisclosed to the judge, and contrary to both chambers policy and the intern’s law-school policy. Judge Neals announced he would issue a written generative-AI prohibition for clerks and interns going forward.
For practitioners, In re CorMedix is a reminder that the verification problem runs both directions. Briefs imported from generative AI are an obvious risk vector, but recent district court opinions citing novel or hard-to-find authority can also be unreliable. A discipline of pin-cite verification before quoting a recent decision protects the firm from inheriting a hallucinated citation through reliance on what looks like primary authority. The case is also useful precedent for raising suspected citation errors directly with chambers via letter rather than pretending not to notice; defense counsel here acted promptly and the court corrected the record without sanctioning anyone.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Treat judicial opinions as potentially fallible primary sources. Verify pin cites and quoted language against the underlying case before relying on a recent opinion in another brief.
- When a published opinion contains a citation that cannot be located, raise the issue in a letter to chambers rather than ignoring or working around the apparent error.
- Document any internal cite-check protocol for citations imported from recent district court opinions, especially for novel propositions of law where a hallucination risk is elevated.
Sources
Primary sources
- The specific text of the July 22, 2025 letter from defense counsel (ECF No. 123) is not retrieved here; substantive details rely on contemporaneous reporting, the docket text of the July 23, 2025 Text Order, and the October 20, 2025 Neals-to-Grassley letter.