American Bar Association Issues Formal Opinion on Use of Generative AI Tools

On July 29, 2024, the American Bar Association issued ABA Formal Opinion 512 titled “Generative Artificial Intelligence Tools.”

The opinion addresses the ethical considerations lawyers are required to consider when using generative AI (GenAI) tools in the practice of law.

The opinion sets forth the ethical rules to consider, including the duties of competence, confidentiality, client communication, raising only meritorious claims, candor toward the tribunal, supervisory responsibilities of others, and setting of fees.

Competence

The opinion reiterates previous ABA opinions that lawyers are required to have a reasonable understanding of the capabilities and limitations of specific technologies used, including remaining “vigilant” about the benefits and risks of the use of technology, including GenAI tools. It specifically mentions that attorneys must be aware of the risk of inaccurate output or hallucinations of GenAI tools and that independent verification is necessary when using GenAI tools. According to the opinion, users must evaluate the tool being used, analyze the output, not solely rely on the tool’s conclusions, and cannot replace their judgment with that of the tool.

Confidentiality

The opinion reminds lawyers that they are ethically required to make reasonable efforts to prevent inadvertent or unauthorized access or disclosure of client information or their representation of a client. It suggests that, before inputting data into a GenAI tool, a lawyer must evaluate not only the risk of unauthorized disclosure outside the firm, but also possible internal unauthorized disclosure in violation of an ethical wall or access controls. The opinion stressed that if client information is uploaded to a GenAI tool within the firm, the client data may be disclosed to and used by other lawyers in the firm, without the client’s consent, to benefit other clients. The client data input into the GenAI tool may be used for self-learning or teaching an algorithm that then discloses the client data without the client’s consent.

The opinion suggests that before submitting client data to a GenAI tool, lawyers must review the tool’s privacy policy, terms of use, and all contractual terms to determine how the GenAI tool will collect and use the data in the context of the ethical duty of confidentiality with clients.

Further, the opinion suggests that if lawyers intend to use GenAI tools to provide legal services to clients, lawyers are required to obtain informed client consent before using the tool. The lawyer is required to inform the client of the use of the GenAI tool, the risk of use of the tool and then obtain the client’s informed consent prior to use. Importantly, the opinion states that “general, boiler-plate provisions [in an] engagement letter” are not sufficient” to meet this requirement.

Communication

With regard to lawyers’ duty to effectively communicate information that is in the best interest of their client, the opinion notes that—depending on the circumstances—it may be in the best interest of the client to disclose the use of GenAI tools, particularly if the use will affect the fee charged to the client, or the output of the GenAI tool will influence a significant decision in the representation of the client. This communication can be included in the engagement letter, though it may be appropriate to communicate directly with the client before including it in the engagement letter.

Meritorious Claims + Candor Toward Tribunal

Lawyers are officers of the court and have an ethical obligation to put forth meritorious claims and to be candid with the tribunal before which such claims are presented. In the context of the use of GenAI tools, as stated above, there is a risk that without appropriate evaluation and supervision (including the use of independent professional judgment), the output of a GenAI tool can sometimes be erroneous or considered a “hallucination.” Therefore, to reiterate the ethical duty of competence, lawyers are advised to independently evaluate any output provided by a GenAI tool.

In addition, some courts require that attorneys disclose whether GenAI tools have been used in court filings. It is important to research and follow local court rules and practices regarding disclosure of the use of GenAI tools before submitting filings.

Supervisory Responsibilities

Consistent with other ABA Opinions relevant to the use of technology, the opinion stresses that managerial responsibilities include providing clear policies to lawyers, non-lawyers, and staff about the use of GenAI in the practice of law. I think this is one of the most important messages of the opinion. Firms and law practices are required to develop and implement a GenAI governance program, evaluate the risk and benefit of the use of a GenAI tool, educate all individuals in the firm on the policies and guardrails put in place to use such tools, and supervise their use. This is a clear message that lawyers and law firms need to evaluate the use of GenAI tools and start working on developing and implementing their own AI governance program for all internal users.

Fees

The key takeaway of the fees section of Opinion 512 is that a lawyer can’t bill a client to learn how to use a GenAI tool. Consistent with other opinions relating to fees, only extraordinary costs associated with the use of GenAI tools are permitted to be billed to the client, with the client’s knowledge and consent. In addition, the opinion points out that any efficiencies gained by the use of GenAI tools, with the client’s consent, should benefit the client through reduced fees.

Conclusion

Although consistent with other ABA opinions related to the use of technology, an understanding of ABA Opinion 512 is important as GenAI tools become more ubiquitous. It is clear that there will be additional opinions related to the use of GenAI tools from the ABA as well as state bar associations and that it is a topic of interest in the context of adherence with ethical obligations. A clear message from Opinion 512 is that now is a good time to consider developing an AI governance program.

A Lawyer’s Guide to Understanding AI Hallucinations in a Closed System

Understanding Artificial Intelligence (AI) and the possibility of hallucinations in a closed system is necessary for the use of any such technology by a lawyer. AI has made significant strides in recent years, demonstrating remarkable capabilities in various fields, from natural language processing to large language models to generative AI. Despite these advancements, AI systems can sometimes produce outputs that are unexpectedly inaccurate or even nonsensical – a phenomenon often referred to as “hallucinations.” Understanding why these hallucinations occur, especially in a closed systems, is crucial for improving AI reliability in the practice of law.

What are AI Hallucinations
AI hallucinations are instances where AI systems generate information that seems plausible but is incorrect or entirely fabricated. These hallucinations can manifest in various forms, such as incorrect responses to prompt, fabricated case details, false medical analysis or even imagined elements in an image.

The Nature of Closed Systems
A closed system in AI refers to a context where the AI operates with a fixed dataset and pre-defined parameters, without real-time interaction or external updates. In the area of legal practice this can include environments or legal AI tools which rely upon a selected universe of information from which to access such information as a case file database, saved case specific medical records, discovery responses, deposition transcripts and pleadings.

Causes of AI Hallucinations in Closed Systems
Closed systems, as opposed to open facing AI which can access the internet, rely entirely on the data they were trained on. If the data is incomplete, biased, or not representative of the real world the AI may fill gaps in its knowledge with incorrect information. This is particularly problematic when the AI encounters scenarios not-well presented in its training data. Similarly, if an AI tool is used incorrectly by way of misused data prompts, a closed system could result in incorrect or nonsensical outputs.

Overfitting
Overfitting occurs when the AI model learns the noise and peculiarities in the training data rather than the underlying patterns. In a closed system, where the training data can be limited and static, the model might generate outputs based on these peculiarities, leading to hallucinations when faced with new or slightly different inputs.

Extrapolation Error
AI models can generalize from their training data to handle new inputs. In a closed system, the lack of continuous learning and updated data may cause the model to make inaccurate extrapolations. For example, a language model might generate plausible sounding but factually incorrect information based upon incomplete context.

Implication of Hallucination for lawyers
For lawyers, AI hallucinations can have serious implications. Relying on AI- generated content without verification could possibly lead to the dissemination or reliance upon false information, which can grievously effect both a client and the lawyer. Lawyers have a duty to provide accurate and reliable advise, information and court filings. Using AI tools that can possibly produce hallucinations without proper checks could very well breach a lawyer’s ethical duty to her client and such errors could damage a lawyer’s reputation or standing. A lawyer must stay vigilant in her practice to safe guard against hallucinations. A lawyer should always verify any AI generated information against reliable sources and treat AI as an assistant, not a replacement. Attorney oversight of outputs especially in critical areas such as legal research, document drafting and case analysis is an ethical requirement.

Notably, the lawyer’s chose of AI tool is critical. A well vetted closed system allows for the tracing of the origin of output and a lawyer to maintain control over the source materials. In the instance of prompt-based data searches, with multiple task prompts, a comprehensive understanding of how the prompts were designed to be used and the proper use of same is also essential to avoid hallucinations in a closed system. Improper use of the AI tool, even in a closed system designed for legal use, can lead to illogical outputs or hallucinations. A lawyer who wishes to utilize AI tools should stay informed about AI developments and understand the limitations and capabilities of the tools used. Regular training and updates can provide a more effective use of AI tools and help to safeguard against hallucinations.

Take Away
AI hallucinations present a unique challenge for the legal profession, but with careful tool vetting, management and training a lawyer can safeguard against false outputs. By understanding the nature of hallucinations and their origins, implementing robust verification processes and maintaining human oversight, lawyers can harness the power of AI while upholding their commitment to accuracy and ethical practice.