# Identifying Legal Holdings with LLMs: A Systematic Study of Performance, Scale, and Memorization

arXiv: https://arxiv.org/abs/2505.02172 · HTML: https://mlsanity.com/paper/2505.02172/

## Key facts

- Cited by 2 papers in the map (data through 14 Oct 2026).
- Builds on 12 of its 25 references that are in the map.
- First posted on arXiv 4 May 2025.

## Builds on (most cited first, 12 of 12)

- [Language Models are Few-Shot Learners](https://mlsanity.com/paper/2005.14165/) (2020)
- [Scaling Laws for Neural Language Models](https://mlsanity.com/paper/2001.08361/) (2020)
- [LegalBench: A Collaboratively Built Benchmark for Measuring Legal Reasoning in Large Language Models](https://mlsanity.com/paper/2308.11462/) (2023)
- [LexGLUE: A Benchmark Dataset for Legal Language Understanding in English](https://mlsanity.com/paper/2110.00976/) (2021)
- [When Does Pretraining Help? Assessing Self-Supervised Learning for Law and the CaseHOLD Dataset](https://mlsanity.com/paper/2104.08671/) (2021)
- [Pile of Law: Learning Responsible Data Filtering from the Law and a 256GB Open-Source Legal Dataset](https://mlsanity.com/paper/2207.00220/) (2022)
- [The Butterfly Effect of Altering Prompts: How Small Changes and Jailbreaks Affect Large Language Model Performance](https://mlsanity.com/paper/2401.03729/) (2024)
- [Exploring LLM Prompting Strategies for Joint Essay Scoring and Feedback Generation](https://mlsanity.com/paper/2404.15845/) (2024)
- [MultiLegalPile: A 689GB Multilingual Legal Corpus](https://mlsanity.com/paper/2306.02069/) (2023)
- [TEaR: Improving LLM-based Machine Translation with Systematic Self-Refinement](https://mlsanity.com/paper/2402.16379/) (2024)
- [Natural Language Processing in the Legal Domain](https://mlsanity.com/paper/2302.12039/) (2023)
- [SoK: Memorization in General-Purpose Large Language Models](https://mlsanity.com/paper/2310.18362/) (2023)

## Built on by (most cited first, 2 of 2)

- [Towards Intelligent Legal Document Analysis: CNN-Driven Classification of Case Law Texts](https://mlsanity.com/paper/2604.17674/) (2026)
- [From Judgments to Issues: Structured Extraction of Legal Reasoning with Citation-Hallucination Control](https://mlsanity.com/paper/2607.03325/) (2026)

## Abstract (arXiv)

As large language models (LLMs) continue to advance in capabilities, it is essential to assess how they perform on established benchmarks. In this study, we present a suite of experiments to assess the performance of modern LLMs (ranging from 3B to 90B+ parameters) on CaseHOLD, a legal benchmark dataset for identifying case holdings. Our experiments demonstrate scaling effects - performance on this task improves with model size, with more capable models like GPT4o and AmazonNovaPro achieving macro F1 scores of 0.744 and 0.720 respectively. These scores are competitive with the best published results on this dataset, and do not require any technically sophisticated model training, fine-tuning or few-shot prompting. To ensure that these strong results are not due to memorization of judicial opinions contained in the training data, we develop and utilize a novel citation anonymization test that preserves semantic meaning while ensuring case names and citations are fictitious. Models maintain strong performance under these conditions (macro F1 of 0.728), suggesting the performance is not due to rote memorization. These findings demonstrate both the promise and current limitations of LLMs for legal tasks with important implications for the development and measurement of automated legal analytics and legal benchmarks.
