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Tuesday, August 19, 2025

Grok Is Not Reliable

I have been fiddling around with various AI ChatBots, comparing them for reliability on searches where I already know the answer. It probably won’t surprise anyone that Elon Musk’s Grok provided the worst results.

Following up my recent column for The Hill, I asked for “the relationship between Judge Edward Loring and Benjamin Robbins Curtis.” Here is Grok’s response, in relevant part:

Edward Greely Loring was a Massachusetts judge and U.S. Commissioner who presided over the Anthony Burns case under the Fugitive Slave Act of 1850.
Benjamin Robbins Curtis, at the time a prominent lawyer and later an Associate Justice of the U.S. Supreme Court (1851–1857), was one of the attorneys who represented Burns in an attempt to secure his freedom.
In summary, Edward Loring and Benjamin Robbins Curtis were professional adversaries in the Anthony Burns case, with Loring acting as the presiding commissioner who enforced the Fugitive Slave Act and Curtis serving as a defense attorney opposing Burns’ return to slavery.

This could not be more wrong regarding Curtis, who was a proponent of the Fugitive Slave Act and led a rally supporting the statute. He played no role in the Anthony Burns trial, but he certainly would not have represented Burns seeking to secure his freedom. In fact, he supported Burns’s return to enslavement. (Curtis was a complicated guy. On the Supreme Court, he dissented from Dred Scott and soon resigned in disgust.) Also, Loring and Curtis were distant cousins of a sort, which Grok completely missed.

I also asked how many times my book The Trials of Rasmea Odeh had been reviewed. Grok hallucinated these three citations, none of which actually exist:

Kirkus Reviews: A review published by Kirkus Reviews describes the book as a “well-documented, shocking, and politically freighted story of a miscarriage of justice.”
Kirkus did not review the book, alas, which is obvious because it is not about a justified outcome, and certainly not a “miscarriage of justice.”
Publishers Weekly: Publishers Weekly provided a review that highlights the book’s examination of Rasmea Odeh’s case, emphasizing Lubet’s meticulous research and narrative skill in detailing her journey from a Palestinian militant to a U.S. citizen and her subsequent legal battles.
This is a more accurate description of the book, but it couldn’t have come from Publishers Weekly, which, I am disappointed to say, never reviewed it.
Law & Society Review: A review by Darryl Li in the Law & Society Review (Volume 56, Issue 4, December 2022) offers a detailed academic critique of the book. Li discusses Lubet’s approach to the legal and political dimensions of Odeh’s case, noting its significance in understanding immigration law and political activism. This review is available through academic databases like Cambridge University Press.
Note the invented details, including the name of the reviewer and the date of the issue. Darryl Li is an anthropologist at the University of Chicago, who works in the areas of law and migration, and currents in the Middle East. I would have loved a review from him in Law & Society, but it never happened.
Two other ChatBots — Perplexity and ChatGPT — got their questions right.

Now, I already knew the answers to my questions on, but it seems unlikely that another user seeking similar information — a student or a young lawyer — would even know how to check for errors.

Posted by Steve Lubet on August 19, 2025 at 09:05 AM | Permalink

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