# Blind to the Human Touch: Overlap Bias in LLM-Based Summary Evaluation

arXiv: https://arxiv.org/abs/2602.07673 · HTML: https://mlsanity.com/paper/2602.07673/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 18 of its 27 references that are in the map.
- First posted on arXiv 7 Feb 2026.

## Builds on (most cited first, 18 of 18)

- [The Llama 3 Herd of Models](https://mlsanity.com/paper/2407.21783/) (2024)
- [Judging LLM-as-a-Judge with MT-Bench and Chatbot Arena](https://mlsanity.com/paper/2306.05685/) (2023)
- [G-Eval: NLG Evaluation using GPT-4 with Better Human Alignment](https://mlsanity.com/paper/2303.16634/) (2023)
- [Get To The Point: Summarization with Pointer-Generator Networks](https://mlsanity.com/paper/1704.04368/) (2017)
- [Teaching Machines to Read and Comprehend](https://mlsanity.com/paper/1506.03340/) (2015)
- [Phi-4-Mini Technical Report: Compact yet Powerful Multimodal Language Models via Mixture-of-LoRAs](https://mlsanity.com/paper/2503.01743/) (2025)
- [JudgeLM: Fine-tuned Large Language Models are Scalable Judges](https://mlsanity.com/paper/2310.17631/) (2023)
- [Humans or LLMs as the Judge? A Study on Judgement Biases](https://mlsanity.com/paper/2402.10669/) (2024)
- [Self-Preference Bias in LLM-as-a-Judge](https://mlsanity.com/paper/2410.21819/) (2024)
- [Is LLM-as-a-Judge Robust? Investigating Universal Adversarial Attacks on Zero-shot LLM Assessment](https://mlsanity.com/paper/2402.14016/) (2024)
- [LongLaMP: A Benchmark for Personalized Long-form Text Generation](https://mlsanity.com/paper/2407.11016/) (2024)
- [MEDEC: A Benchmark for Medical Error Detection and Correction in Clinical Notes](https://mlsanity.com/paper/2412.19260/) (2024)
- [Split and Merge: Aligning Position Biases in LLM-based Evaluators](https://mlsanity.com/paper/2310.01432/) (2023)
- [Large Language Models are Not Yet Human-Level Evaluators for Abstractive Summarization](https://mlsanity.com/paper/2305.13091/) (2023)
- [One Token to Fool LLM-as-a-Judge](https://mlsanity.com/paper/2507.08794/) (2025)
- [Explaining Length Bias in LLM-Based Preference Evaluations](https://mlsanity.com/paper/2407.01085/) (2024)
- [Are Large Language Models Reliable Judges? A Study on the Factuality Evaluation Capabilities of LLMs](https://mlsanity.com/paper/2311.00681/) (2023)
- [Understanding Generative AI Capabilities in Everyday Image Editing Tasks](https://mlsanity.com/paper/2505.16181/) (2025)

## Abstract (arXiv)

Large language model (LLM) judges have often been used alongside traditional, algorithm-based metrics for tasks like summarization because they better capture semantic information, are better at reasoning, and are more robust to paraphrasing. However, LLM judges show biases for length and order among others, and are vulnerable to various adversarial input prompts. While recent studies have looked into these biases, few have analyzed them at a more granular level in relation to a well-defined overlap metric. In this work we provide an LLM judge bias analysis as a function of overlap with human-written responses in the domain of summarization. We test 9 recent LLMs with parameter counts ranging from 1 billion to 12 billion, including variants of Gemma 3 and LLaMA 3. We find that LLM judges increasingly prefer summaries generated by other LLMs over those written by humans as the similarities (as measured by ROUGE and BLEU) between the judged summaries decrease, and this pattern extends to all but one model tested, and exists regardless of the models' own position biases. Additionally, we find that models struggle to judge even summaries with limited overlaps, suggesting that LLM-as-a-judge in the summary domain should rely on techniques beyond a simple comparison.