mlsanityData to 7 Oct 2026

Gavel: Agent Meets Checklist for Evaluating LLMs on Long-Context Legal Summarization

arXiv 2601.04424 ↗First posted 7 Jan 2026cs.CLcited by 0

On the map: LLM agents and tool use → Social simulation and multi-agent debate

Abstract (arXiv)

Large language models (LLMs) now support contexts of up to 1M tokens, but their strengths and weaknesses on complex long-context tasks remain unclear. To study this, we focus on multi-document legal case summarization, where a single case often spans many documents exceeding 100K tokens. We systematically evaluate 12 frontier LLMs with Gavel, which consists of Gavel-Ref, a reference-based evaluation framework with checklist, residual-fact, and writing-style evaluations, and Gavel-Agent, a reference-free agent for evaluating factual coverage directly from source documents. Our results show that current models are more prone to omitting key information than hallucinating. They all perform well on simple checklist items, such as filing date, but struggle with rare and complex items, such as settlements. Performance also declines as case length increases. To meta-evaluate Gavel, we collect 160 hours of human annotations. Gavel-Agent reduces token usage by at least 36% compared to end-to-end and chunk-by-chunk methods while achieving competitive performance. Gavel-Agent also generalizes to the medical domain, performing the best with at least 77% fewer tokens.

Key facts. No citing papers in the map yet (data through 7 Oct 2026). Placed in Social simulation and multi-agent debate, one of 16 directions in LLM agents and tool use. Builds on 24 of its 62 references that are in the map. First posted on arXiv 7 Jan 2026.

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24 of 62 references.

References · 24

  1. 2023Efficient Memory Management for Large Language Model Serving with PagedAttentioncited by 5,767
  2. 2020Big Bird: Transformers for Longer Sequencescited by 1,673
  3. 2018Don't Give Me the Details, Just the Summary! Topic-Aware Convolutional Neural Networks for Extreme Summarizationcited by 1,308
  4. 2023FActScore: Fine-grained Atomic Evaluation of Factual Precision in Long Form Text Generationcited by 1,259
  5. 2024OpenHands: An Open Platform for AI Software Developers as Generalist Agentscited by 956
  6. 2023Extending Context Window of Large Language Models via Positional Interpolationcited by 721
  7. 2019Text Summarization with Pretrained Encoderscited by 553
  8. 2023A Real-World WebAgent with Planning, Long Context Understanding, and Program Synthesiscited by 350
  9. 2024WildBench: Benchmarking LLMs with Challenging Tasks from Real Users in the Wildcited by 211
  10. 2024Chain of Agents: Large Language Models Collaborating on Long-Context Taskscited by 201
  11. 2023BooookScore: A systematic exploration of book-length summarization in the era of LLMscited by 137
  12. 2023Walking Down the Memory Maze: Beyond Context Limit through Interactive Readingcited by 129
12 more
  1. 2024HELMET: How to Evaluate Long-Context Language Models Effectively and Thoroughlycited by 119
  2. 2023WiCE: Real-World Entailment for Claims in Wikipediacited by 118
  3. 2025Alita: Generalist Agent Enabling Scalable Agentic Reasoning with Minimal Predefinition and Maximal Self-Evolutioncited by 114
  4. 2024TICKing All the Boxes: Generated Checklists Improve LLM Evaluation and Generationcited by 62
  5. 2023PEARL: Prompting Large Language Models to Plan and Execute Actions Over Long Documentscited by 61
  6. 2024Decomposition Dilemmas: Does Claim Decomposition Boost or Burden Fact-Checking Performance?cited by 34
  7. 2024FENICE: Factuality Evaluation of summarization based on Natural language Inference and Claim Extractioncited by 28
  8. 2022ArgLegalSumm: Improving Abstractive Summarization of Legal Documents with Argument Miningcited by 25
  9. 2024FactPICO: Factuality Evaluation for Plain Language Summarization of Medical Evidencecited by 18
  10. 2025Are Checklists Really Useful for Automatic Evaluation of Generative Tasks?cited by 9
  11. 2023Thresh: A Unified, Customizable and Deployable Platform for Fine-Grained Text Evaluationcited by 6
  12. 2024CaseSumm: A Large-Scale Dataset for Long-Context Summarization from U.S. Supreme Court Opinionscited by 5

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  1. 2023One Law, Many Languages: Benchmarking Multilingual Legal Reasoning for Judicial Support
  2. 2025LegalEval-Q: A New Benchmark for The Quality Evaluation of LLM-Generated Legal Text
  3. 2026Evaluation of Large Language Models in Legal Applications: Challenges, Methods, and Future Directions
  4. 2026Multi-Legal-Bench: Evaluating LLMs on Legal Reasoning Across Jurisdictions, Languages, and Legal Traditions
  5. 2026ContractScrub: A benchmark for final review of legal contracts
  6. 2025LeMAJ (Legal LLM-as-a-Judge): Bridging Legal Reasoning and LLM Evaluation
  7. 2025Towards Reliable Retrieval in RAG Systems for Large Legal Datasets
  8. 2026BenGER Platform: A Collaborative Web Platform for End-to-End Benchmarking of German Legal Tasks