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0 | The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the ... | al-hamim_v._star_hearthstone_llc.pdf | [
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] | null | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
1 | No. 24CA0190, Al-Hamim v. Star Hearthstone, LLC -Landlords and Tenants - Warranty of Habitability - Implied Covenant of Quiet Enjoyment; Technology - Artificial Intelligence - Generative AI Tools - Hallucinations; Colorado Rules of Appellate Procedure - Briefs - Citation to Authorities - Sanctions for Non-Compliance
Si... | al-hamim_v._star_hearthstone_llc.pdf | [
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] | 2024COA128 | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
2 | Division I Opinion by JUDGE LIPINSKY J. Jones and Sullivan, JJ., concur
Announced December 26, 2024
Alim Al-Hamim, Pro Se
Gordon Rees Scully Mansukhani LLP, John R. Mann, Greg S. Hearing II, Brittney T. Bulawa, Denver, Colorado, for Defendants-Appellees
- ¶ 1 The recent advances in artificial intelligence (AI), and tex... | al-hamim_v._star_hearthstone_llc.pdf | [
3,
4
] | JUDGMENT AFFIRMED | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
3 | GAI hallucination ' occurs when an AI system provides information that is inaccurate or, more bluntly, fake. ').
- ¶ 3 Some self-represented litigants, including plaintiff, Alim Al-Hamim, have relied on GAI tools to draft court filings, only to discover later to their chagrin that their filings contained hallucinations... | al-hamim_v._star_hearthstone_llc.pdf | [
5,
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] | JUDGMENT AFFIRMED | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
4 | - ¶ 5 Star Hearthstone rented an apartment to Al-Hamim and his cotenants in April 2020. Al-Hamim alleged in his complaint that IRT Living managed the apartment complex for a portion of the time he rented the apartment.
- ¶ 6 Al-Hamim pleaded that, in early 2021, shortly after he moved into the apartment, he 'noticed a... | al-hamim_v._star_hearthstone_llc.pdf | [
6,
7
] | I. Background | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
5 | - ¶ 8 Al-Hamim asserted that '[n]early an entire year passed with no action on the part of [the landlords] ' and that he ' still had not actually moved into and settled into the premises. ' However, despite his concerns about the cat urine odor and carpet stains, Al-Hamim renewed his lease through mid-2023.
- ¶ 9 Al-Ha... | al-hamim_v._star_hearthstone_llc.pdf | [
7
] | I. Background | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
6 | - ¶ 10 Al-Hamim contends that the court erred by granting the landlords ' motion to dismiss. Specifically, he argues that the court of habitability and the implied covenant of quiet enjoyment.
- erred by determining that the landlords did not breach the warranty Additionally, he asserts that the court improperly faile... | al-hamim_v._star_hearthstone_llc.pdf | [
8
] | II. The Court Did Not Err by Dismissing the Case | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
7 | - ¶ 11 Because Al-Hamim represented himself throughout the case, we must liberally interpret his complaint and response to the landlords' dismissal motion . See People v. Bergerud , 223 P.3d 686, 697 (Colo. 2010). But Al-Hamim 's status as a self-represented litigant does not excuse his noncompliance with the procedur... | al-hamim_v._star_hearthstone_llc.pdf | [
8
] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
8 | as true and view them in the light most favorable to the nonmoving party to determine whether the plaintiff has alleged ' sufficient facts that, if taken as true, show plausible grounds to support a claim for relief. ' Jagged Peak Energy Inc. v. Okla. Police Pension & Ret. Sys. , 2022 CO 54, ¶ 25, 523 P.3d 438, 446 (ci... | al-hamim_v._star_hearthstone_llc.pdf | [
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] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
9 | - ¶ 14 A landlord breaches the warranty of habitability if the residential premises is (1) ' [u]ninhabitable, ' as defined in section 38-12-505, C.R.S. 2023, § 38-12-503(2)(a)(I); or (2) ' [i]n a condition that materially interferes with the tenant ' s life, health, or safety, ' § 38-12-503(2)(a)(II). Section 38-12-50... | al-hamim_v._star_hearthstone_llc.pdf | [
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] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
10 | statute because Al-Hamim did not allege that the cat odor or urine stains affected his life or safety. Viewing the allegations in the complaint in the light most favorable to Al-Hamim, see Jagged Peak Energy Inc. , ¶ 25, 523 P.3d at 446, his allegation that the cat urine smell and stains impacted his health rested on ... | al-hamim_v._star_hearthstone_llc.pdf | [
11
] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
11 | - ¶ 17 For these reasons, we hold that the court did not err by concluding that Al-Hamim failed to plead an actionable claim for breach of the warranty of habitability.
- C. Implied Covenant of Quiet Enjoyment
- ¶ 18 ' [I]n the absence of an agreement to the contrary, there is an implied covenant for the quiet enjoymen... | al-hamim_v._star_hearthstone_llc.pdf | [
12
] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
12 | 'disturbance of [the] lessee's possession by his lessor' rendered the premises ' unfit . . . for the purposes for which they were leased. ' W. Stock Ctr., Inc. , 578 P.2d at 1051 (quoting Radinsky , 460 P.2d at 220).
- ¶ 19 Al-Hamim alleged that '[t]he landlord [s ' ] refusal to replace the cat-urine-stained carpet, de... | al-hamim_v._star_hearthstone_llc.pdf | [
13
] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
13 | occupancy. (In his response to the landlords' motion to dismiss and in the opening brief, Al-Hamim argued that the carpet problems prevented him from using his bedroom. However, he did not include this allegation in his complaint and, therefore, we do not consider it. See Norton , ¶ 7, 409 P.3d at 334 (' When conside... | al-hamim_v._star_hearthstone_llc.pdf | [
14
] | A. Standard of Review | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
14 | ¶ 23 Al-Hamim raises the following claims for the first time in his opening brief:
- The landlords 'breached the lease agreement and the implied covenant of good faith and fair dealing by failing to resolve maintenance issues and by conducting arbitrary credit checks.'
- '[T]he leasing agent made fraudulent representat... | al-hamim_v._star_hearthstone_llc.pdf | [
15,
16
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
15 | - III. Court Filings with GAI-Produced Hallucinations
- A. The Hallucinations in AlHamim's Opening Brief
3. ¶ 25 AlHamim's opening brief contains citations to the following fake cases:
- Beck v. Tibbetts , 967 P.2d 150 (Colo. 1998);
- Jankowski v. Cross , 672 P.2d 1178 (Colo. App. 1983);
- L&M Inv. Co. v. Morrison , 46... | al-hamim_v._star_hearthstone_llc.pdf | [
16,
17
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
16 | - B. The Risks of Relying on a GAI Tool to Draft a Court Filing ¶ 27 To explain why a GAI tool can produce legal documents filled with hallucinations, we briefly review the large language model (LLM) underlying GAI technology.
2. ¶ 28 GAI tools are trained using LLMs that, ' through a form of machine learning known as ... | al-hamim_v._star_hearthstone_llc.pdf | [
17,
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] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
17 | - ¶ 29 The limitations of and biases contained in the materials used to train an LLM can produce outputs that reflect the shortcomings in the LLM's training. As of mid -2024, popular GAI tools, such as OpenAI's GPT -4, were not ' trained with data sets containing comprehensive, accurate legal resources. ' Id. These wi... | al-hamim_v._star_hearthstone_llc.pdf | [
18
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
18 | case citation, and/or the content or holding of a fake case or a real judicial decision.' Id. ; see also Eve Ross & Amy Milligan, What Can ChatGPT Do, and Should We Let It? , 34 S.C. Law. 34, 36 (2023) ('ChatGPT may confidently include authorities in its responses that are misleading, incorrect or simply made up. . . .... | al-hamim_v._star_hearthstone_llc.pdf | [
19,
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] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
19 | - ¶ 32 Accordingly, using a GAI tool to draft a legal document can pose serious risks if the user does not thoroughly review the tool's output. Reliance on a GAI tool not trained with legal authorities can ' lead both unwitting lawyers and nonlawyers astray. ' Access to Justice , 53 Colo. Law. at 43. A self-represent... | al-hamim_v._star_hearthstone_llc.pdf | [
20,
21
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
20 | , N.Y. Times (May 27, 2023),
Your Lawyer Uses ChatGPT
https://perma.cc/H4DC-JWH2; Larry Neumeister, Lawyers Submitted Bogus Case Law Created by ChatGPT. A Judge Fined Them $5,000 , Associated Press (June 22, 2023), https://perma.cc/2B27-PHJN. By mid-2024, GAI tools' propensity to produce hallucinations in response to... | al-hamim_v._star_hearthstone_llc.pdf | [
21,
22
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
21 | 2024 WL 3460049, at *7 (S.D.N.Y. July 18, 2024) (unpublished opinion). The court noted that ' [s]anctions may be imposed for submitting false and nonexistent legal authority to the [c]ourt. ' Id. However, the court declined to impose sanctions due to the plaintiff ' s status as a self-represented litigant and, instead... | al-hamim_v._star_hearthstone_llc.pdf | [
23
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
22 | Morgan v. Cmty. Against Violence , No. 23-cv-353-WPJ/JMR, 2023 WL 6976510, at *8 (D.N.M. Oct. 23, 2023) (unpublished opinion) (asserting that the self-represented status of a plaintiff who ' cited to several fake or nonexistent opinions ' will ' not be tolerated by the [c]ourt as an excuse for failing to adhere to this... | al-hamim_v._star_hearthstone_llc.pdf | [
24,
25
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
23 | - ¶ 39 While we conclude that AlHamim's submission of a brief containing hallucinations violated C.A.R. 28(a)(7)(B), this deviation from the Appellate Rules was not as serious as the self-represented appellant's misconduct in Kruse . Further, in his response to our show cause order, Al-Hamim acknowledged his use of AI... | al-hamim_v._star_hearthstone_llc.pdf | [
25,
26
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
24 | - ¶ 41 However, we warn Al-Hamim, as well as lawyers and self-represented parties who appear in this court, that we will not ' look kindly on similar infractions in the future.' Anonymous , 2024 WL 3460049, at *7. A lawyer 's or a self-represented party 's future filing in this court containing GAI-generated hallucina... | al-hamim_v._star_hearthstone_llc.pdf | [
26
] | D. Other Issues | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
25 | - The judgment is affirmed. JUDGE J. JONES and JUDGE SULLIVAN concur.
- ¶ 42 | al-hamim_v._star_hearthstone_llc.pdf | [
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] | IV. Disposition | al-hamim_v._star_hearthstone_llc_chunks_400.jsonl_chunks.json |
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