North Carolina — AI Regulations

26 MAR 2026 · Court Case

Curry v. Capital One Auto Finance

Fabricated: Legal Norm | Proposed amended complaint asserted fictitious provisions of a purported North Carolina Identity Theft Protection Act (ITPA); the court identified these statutory provisions as fabricated and tied them to likely AI drafting. || Fabricated: Case Law | Second proposed amended complaint contained fabricated case citations; the court found the inclusion of fabricated citations constituted bad faith and a basis to deny leave to amend.

Court: E.D. North CarolinaParty: Pro Se Litigant

Harms: Hallucination in legal filings

18 MAR 2026 · Court Case

Forest Ridge Townhomes Corporation of Greensboro v. Heag Pain Management Cente et al.

Fabricated: Exhibits & Submissions | Respondents submitted an exhibit titled 'Perplexity.AI Answers' containing AI-generated legal authorities and links; the court found some cited authorities irrelevant and appearing to be hallucinated and noted counsel's admission of using Perplexity.AI.

Court: CA North CarolinaParty: LawyerTool: Perplexity.AI

Harms: Hallucination in legal filings

10 MAR 2026 · Court Case

United States of America v. Lorenzio Reshaud Simmons

Fabricated: Case Law | Memorandum cited 'United States v. Hazel, 696 F.3d 473, 478 (4th Cir. 2012)' — court found no such Fourth Circuit case (citation appears fabricated). || Fabricated: Case Law | Memorandum cited 'United States v. Angel, 102 F.3d 1066 (4th Cir. 1996)' for a quoted rule; court found no such Fourth Circuit decision or matching quoted language. || Misrepresented: Case Law | Memorandum cited 'United States v. Brehm, 442 F.3d 1291, 1293 (4th Cir. 2006)' and attributed the quote 'any uncertainty should be resolved in the defendant's favor.' The court noted the cited Brehm reference is to a different circuit and does not contain that quoted language. || Misrepresented: Case Law | Memorandum cited 'United States v. Nealy, 232 F.3d 825, 829 (4th Cir. 2000)' for language about burdens the government cannot meet; court found the citation is to a different circuit and does not contain the asserted language. || False Quotes: Case Law | Memorandum cited 'United States v. Edwards, 188 F.3d 230, 232 (4th Cir. 1999)' and quoted that packaging weight should not be included; court found Edwards does not contain that quoted language (false quotation). || Misrepresented: Case Law | Memorandum cited 'United States v. Harrision, 918 F.2d 469, 473 (4th Cir. 1990)' for a statement that laboratory testing is more precise; court noted the correct case is in a different circuit (Fifth) and does not contain that quoted text.

Court: E.D. North CarolinaParty: LawyerTool: Unidentified

Harms: Hallucination in legal filings

02 MAR 2026 · Court Case

Derence V. Fivehouse v. United States Department of Defense et al.

Fabricated: Legal Norm | Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing summary judgment (D.E.90). || Fabricated: Case Law | Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: judicial notice (D.E.80). || Fabricated: Legal Norm | Court identified a fabricated quotation from regulation 32 C.F.R. § 199.21(d) in Defendants' response opposing preliminary injunction (D.E.39). || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Ohio Valley Environmental Coalition v. Aracoma Coal Co.; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Dow AgroSciences, LLC v. National Marine Fisheries Service; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified fabricated quotations/misstatements in D.E.86 attributing holdings to Sierra Club v. United States Dept. of the Interior; Renfer conceded incorrect citations. || Fabricated: Case Law | Court identified a fabricated quotation attributed to South Carolina Health & Human Services Finance Comm'n v. Sullivan in Defendants' response re: Appellate Rule 16 (D.E.79).

Court: E.D. North CarolinaParty: Lawyer

Harms: Hallucination in legal filings

24 FEB 2026 · Court Case

Ebony Sherisse Lucas v. Charles W. Scharf, et al.

Fabricated: Case Law | Court identified this citation in plaintiff's reply as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's response as non-existent and likely AI-generated. || Fabricated: Case Law | Court identified this citation in plaintiff's reply as non-existent and likely AI-generated. || Misrepresented: Case Law | Court noted this is a real case but found plaintiff cited it for a proposition the case does not support.

Court: W.D. North CarolinaParty: Pro Se Litigant

Harms: Hallucination in legal filings

13 JAN 2026 · Court Case

Reketta L. Montgomery v. Acquisition Experts, LLC

Fabricated: Case Law | Defendant identified numerous fictitious or fake case citations in both memoranda filed by the pro se plaintiff; the court found the citations to be fictitious and relied on that finding in denying leave to amend.

Court: E.D. North CarolinaParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

10 NOV 2025 · Court Case

Jacob Doe v. The University of North Carolina System

Fabricated: Case Law | Plaintiff cited two cases that the Court found do not appear to exist. || False Quotes: Case Law | Plaintiff quoted material that does not exist in the cases purportedly quoted. || Misrepresented: Case Law | Court identified mischaracterizations of the holdings of cited cases in the Plaintiff's briefs. || Misrepresented: Case Law | An out-of-circuit case was misidentified in the briefs as a Fourth Circuit case.

Court: W.D. North CarolinaParty: Lawyer

Harms: Hallucination in legal filings

17 SEP 2025 · Court Case

Santree v. Eveangel Hines

Fabricated: Case Law | Defendant cited a State v. Boggess published in 1979 that does not exist; the court found no Supreme Court opinion by that name in 1979 (only a 2004 State v. Boggess exists and does not support her points). || Misrepresented: Case Law | Defendant attributed several legal propositions to Cheek v. Poole that the case does not state; court found Cheek does not support the cited propositions.

Court: CA North CarolinaParty: Pro Se Litigant

Harms: Hallucination in legal filings

01 DEC 2024 · Law / Act

North Carolina House Bill 591

Defines "image" to include AI-modified depictions, criminalizing sexual extortion involving such images. Criminalizes creating or modifying visual depictions of minors using AI under sexual exploitation offenses. Clarifies disclosure offenses involving AI-altered private images, making violations a felony or misdemeanor.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2ncleg.gov ↗

21 AUG 2024 · Standard / Framework

North Carolina State Government Responsible Use of Artificial Intelligence Framework

Require state agencies to follow the AI Framework, which emphasizes principles such as human oversight, transparency, security, data privacy, diversity, auditing, and workforce empowerment. Obligate agencies to maintain AI inventories and conduct risk assessments using the NIST AI Risk Management Framework.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2it.nc.gov ↗

03 OCT 2023 · Law / Act

North Carolina House Bill 259

Allocates $3.2 million to New Hanover and $2 million to Davidson County Schools for AI-powered school safety systems. Requires reporting by January 15, 2025, on participant schools, spending, safety outcomes, AI capabilities, and additional relevant information.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+2ncleg.gov ↗

30 MAR 2023 · Other

North Carolina SB 460

Establishes a Study Committee on Automation and the Workforce to assess the impact of automation technologies, including AI, on North Carolina's workforce, especially low-income and minority workers. Requires biennial reports with recommendations to the Governor and legislature.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+6ncleg.gov ↗