Virginia — AI Regulations

12 MAR 2026 · Court Case

Suiter v. GM - General Motors, LLC

Fabricated: Case Law | Suiter cited numerous case authorities that the court found to be fabricated or nonexistent; GM moved to strike the filings on that basis. || False Quotes: Case Law | Suiter included quotations attributed to cited cases that the court determined do not appear in those cases (nonexistent quotes). || Misrepresented: Case Law | Court observed that several cited cases were mischaracterized or quoted inaccurately, reflecting characteristics of generative-AI outputs.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

24 FEB 2026 · Court Case

Gail Fung v. Liberty University

Fabricated: Case Law | Plaintiff cited 'Friedman v. Southern New Hampshire University, 104 A.D. 3d 617 (N.Y. App. Div. 2013)'; the Court found no such case exists and that it does not support the plaintiff's argument, warning of potential Rule 11 sanctions.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

27 JAN 2026 · Court Case

Brian Bailey v. Hon. Clark A. Ritchie, et al.

Fabricated: Case Law | State court observed plaintiff's filings contained citations to nonexistent authorities; federal court noted this suspicion of AI-generated, fabricated citations.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

23 JAN 2026 · Court Case

United States v. Michael Shane DeBaere (2)

False Quotes: Case Law | Lengthy quotation attributed to United States v. Melvin (3d Cir.) that does not appear in that opinion; court found the quoted material absent from Melvin. || Misrepresented: Case Law | Mischaracterization of United States v. Emmett (9th Cir.), including attributing analysis and a quotation that the Emmett opinion does not contain. || Fabricated: Case Law | Multiple citations on memorandum page 11 to cases that are not found (citation strings do not match any real cases or the quoted language does not appear in the cited opinions). || False Quotes: Case Law | Quotation "static rehashing of past severity" attributed to a case where the phrase does not appear and no source could be located.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

01 JAN 2026 · Law / Act

Virginia SB 245

Virginia legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

01 JAN 2026 · Law / Act

Virginia HB 713

Virginia legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

01 JAN 2026 · Law / Act

Virginia SB 365

Virginia legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Generative AI ·Data Privacy & Protectiongoogle.com ↗

19 DEC 2025 · Court Case

Gavin Simpson v. Portfolio Recovery Associates, LLC

False Quotes: Case Law | Plaintiff’s filings included fabricated quotes; court identified these as fabricated quotations and warned against such submissions. || Fabricated: Legal Norm | Plaintiff cited a non-existent statutory provision and misattributed statutory language. || Misrepresented: Case Law | Plaintiff submitted mischaracterized case citations (attributing holdings/quotes incorrectly).

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

16 DEC 2025 · Court Case

Michael Redwine v. Unum Life Insurance Company of America

Fabricated: Case Law | Plaintiff cited McBeth v. Metro Life Ins. Co., 2006 WL 2792439 (E.D. Va. Sept. 26, 2006); the Court could not locate the case and notes the plaintiff admitted it was generated by AI tools.

Court: W.D. VirginiaParty: Pro Se LitigantTool: Unidentified

Harms: Hallucination in legal filings

09 DEC 2025 · Court Case

Scott M. Boger v. City of Harrisonburg, Virginia, et al.

Misrepresented: Case Law | Plaintiff cited 'Snider Int’l Corp. v. City of Norfolk, 739 F.3d 140, 150 (4th Cir. 2014)'; the court could not identify a case by that name and noted the reporter corresponds to Snider Int’l Corp. v. Town of Forest Heights, Md., 739 F.3d 140, which does not support plaintiff's assertion. || False Quotes: Case Law | Plaintiff quoted language he attributed to Connelly v. Steel Valley Sch. Dist., 706 F.3d 209, 216 (3d Cir. 2013); the court found the quoted language appears to have been fabricated and does not appear in that opinion.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

08 DEC 2025 · Court Case

Brian Jeffrey Hall Jr. v. Halsted Financial Services, LLC

Fabricated: Case Law | Plaintiff cited 'Younger v. Experian, 2023 WL 3260198 (E.D. Pa. May 4, 2023)'; the court was unable to locate the decision on research databases and concluded it likely does not exist.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

18 SEP 2025 · Court Case

Eric V. Mitchel II v. Stellantis Financial Services

Fabricated: Case Law | Plaintiff cited "Smith v. Stellantis Financial Services, Inc., Case No. 3:18-cv-00512 (E.D. Va. 2018)"; the Court found the cited case number actually corresponds to Miller v. General District Court of the City of Richmond, indicating an inaccurate/fabricated citation. || Fabricated: Case Law | Plaintiff cited "Garcia v. Stellantis Fin. Servs., 4:21-cv-00354 (W.D. Tex. 2021)"; the Court found no Westlaw result for that citation and noted the actual W.D. Tex. 4:21-cv-354 corresponds to Franklin v. Apple Inc., 569 F. Supp. 3d 465 (W.D. Tex. 2021). || Fabricated: Case Law | The Court observed that nearly every citation listed under Plaintiff's sub-heading "VII. Established Pattern of Unfair Practices by Stellantis" appears incorrect or fabricated, suggesting multiple AI-generated hallucinated authorities.

Court: E.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

27 AUG 2025 · Court Case

United States v. Michael Shane DeBaere (1)

Fabricated: Doctrinal Work | DeBaere cited a non-existent provision of the Guide to Judiciary Policy (Vol. 8, Pt. E, § 220.40) and quoted language that the court determined does not exist; court found the quotation fabricated and provided no basis for disclosure. || Fabricated: Case Law | DeBaere relied on a fabricated Sixth Circuit decision cited as United States v. Zai, 939 F.3d 740, 746 (6th Cir. 2019), including a quoted passage that the court determined was invented; court rejected the authority as non-existent/misleading. || Fabricated: Case Law | DeBaere cited United States v. Parisi, 363 F. Supp. 3d 281 (W.D.N.Y. 2019) as support for early termination; the court determined that citation is fabricated and provides no support. || Fabricated: Case Law | The defendant's filings contained numerous additional fabricated or mischaracterized cases and quotations (the brief contained over 70 citations the court described as fabricated or mischaracterized); the court emphasized the defendant's responsibility to verify authorities.

Court: W.D. VirginiaParty: Pro Se Litigant

Harms: Hallucination in legal filings

02 JUN 2025 · Court Case

Powhatan County School Board v. Skinger et al

Misrepresented: Case Law | Cited T.A. v. McKinney Independent School District, 861 F.2d 655 (5th Cir. 1988), but that reporter cite corresponds to Jones v. Otis Elevator Co., 861 F.2d 655 (11th Cir. 1988), unrelated. || Fabricated: Case Law | Used an improbable case name with no citation; court found it entirely fabricated and nonexistent. || Fabricated: Case Law | Provided only a name and year; targeted search found no such case; court deemed it nonexistent. || Fabricated: Case Law | Provided only a name and year without citation; court could not identify any such decision and treated it as nonexistent. || Fabricated: Case Law | Asserted a case tied to opposing counsel with no citation; targeted search found none; court found it nonexistent. || Fabricated: Case Law | Referenced a non-case caption without a proper case name or citation; court treated it as fabricated. || Misrepresented: Case Law | Cited a Fourth Circuit decision that does not exist; closest match is a Sixth Circuit criminal case and a much later district court case with no relevance. || Fabricated: Case Law | Cited an unfindable Second Circuit case; closest match is Lin Zhong v. DOJ, 489 F.3d 126 (2d Cir. 2007); court found the cited case nonexistent. || Misrepresented: Case Law | Misstated circuit and case; the provided cite corresponds to a First Circuit civil case, not a Third Circuit decision as cited. || Fabricated: Case Law | Provided a Second Circuit citation that does not exist; closest is an unrelated Fifth Circuit case; court deemed it nonexistent. || Fabricated: Case Law | Provided a Second Circuit citation that does not exist; closest match is a criminal case; court deemed it nonexistent and irrelevant. || Fabricated: Case Law | Cited a Ninth Circuit decision at a page number that does not exist; closest is a Tenth Circuit environmental case; court deemed it nonexistent for the proposition cited. || Fabricated: Case Law | Cited an unfindable Seventh Circuit decision; closest is a Sixth C

Court: E.D. VirginiaParty: Pro Se LitigantTool: ChatGPT

Harms: Hallucination in legal filings

25 MAR 2025 · Court Case

Kruglyak v. Home Depot U.S.A., Inc.

Fabricated: Case Law | Plaintiff cited fictitious case citations in his reply to the opposition to the motion to compel (Dkt. 123); he conceded this; the court found negligence but no bad faith and declined monetary sanctions. || Misrepresented: Case Law | Plaintiff misrepresented the holdings of various cases in the same reply brief (Dkt. 123); he conceded this; the court found negligence but no bad faith and declined monetary sanctions.

Court: W.D. VirginiaParty: Pro Se LitigantTool: ChatGPT

Harms: Hallucination in legal filings

24 MAR 2025 · Other

Virginia 2025-HB2094

Establishes operating standards for developers and deployers of high-risk AI systems, including mandatory risk management and impact assessments. Requires disclosures of potential algorithmic discrimination risks.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+25lis.virginia.gov ↗

09 APR 2024 · Law / Act

Virginia HB 747: High-Risk Artificial Intelligence Developer and Deployer Act

The Virginia legislature passed House Bill 747, establishing obligations for developers and deployers of high-risk AI systems affecting Virginia residents, including requirements to conduct impact assessments, implement risk management policies, and provide consumers with notice and the right to appeal adverse AI decisions. The bill was passed by the General Assembly but vetoed by Governor Glenn Youngkin in March 2024, who cited concerns about regulatory burdens on businesses and the need for a more targeted approach. The veto drew significant attention to the challenge of balancing AI consumer protections with innovation-friendly business environments.

✓ ✓ OfficialData Privacy & Protection ·Labor & Workforcelis.virginia.gov ↗

08 APR 2024 · Law / Act

Virginia Senate Bill 487

Requires JCOTS to analyze AI use by public bodies, focusing on procurement, implementation, and discrimination prevention. Instructs JCOTS to assess creating a Commission on AI to advise on related issues. Mandates JCOTS's report submission to legislative committees by December 1, 2024.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+12legacylis.virginia.gov ↗

28 MAR 2024 · Other

Virginia 2024 SB 731

Amends the state's definition of child pornography to explicitly include visual material where "the minor depicted does not have to actually exist". Establishes mandatory prison sentences based on the age difference and repeat offenses, with substantial penalties for violations.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+8legacylis.virginia.gov ↗

20 SEP 2023 · Other

Virginia Executive Directive 5 (2023)

Directs the Office of Regulatory Management to establish AI standards, review laws, ensure transparency, and make recommendations for AI use. Tasks coordination with education and workforce institutions for AI guidelines. Requires completion of actions by December 15, 2023.

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

18 MAR 2021 · Other

Virginia HB 2154

Requires hospitals and nursing facilities to establish policies for patient access to intelligent personal assistants. Ensures HIPAA compliance. Defines intelligent personal assistants as devices using AI and natural language processing. Mandates facility compliance with privacy and security standards.

✓ ✓ OfficialFinancial Services ·Education ·Health & Life Sciences ·+4lis.virginia.gov ↗