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Sanctions watch

Every incident where a lawyer got caught filing AI-fabricated citations. The Hall of Shame.

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851
Incidents tracked
262
Incidents in 2026
$2,417,608
In fines, where reported
214 of 851 report an amount

The curve

Incidents per month

Last 18 months of published incidents, by the date of the court's order.

Apr 2025 Sep 2026

Charting 446 of 851 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 151 Claude 9 CoCounsel 8 Copilot 8 Gemini 8 Lexis+ AI 6 AI-assisted legal software 4 Westlaw Precision 4 ChatGPT-4o 2 ChatOn 2 Eve 2 Google AI 2 LEAP 2 Perplexity AI 2 AI Overviews 1 Archie 1 Centient AI 1 ChatGPT-4 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 GPT-3.5 1 Ghostwriter Legal 1 Google Scholar 1 Grammarly 1 Grok 1 Irys 1 Legal Genius 1 LegalAI 1 MX2.law 1 OpenCase 1 Strongsuit 1 vLex Fastcase 1

Counts only incidents where the filing court or the reporting named the tool.

Hall of Shame

All Fined 251 Caught, not sanctioned 199 Warned 126 Referred to the bar 98 Reprimanded 85 Outcome unclear 53 Filing dismissed 36 Suspension 2 Upcoming sanction 1
Fined $15K
An Illinois appellate court imposed a $15,000 sanction on an attorney for citing hallucinated AI-generated case law in a legal brief.
In re Marriage of Edwards · Illinois Appellate Court, Second District · IL
jdsupra.com ↗
The file →
  • In re Marriage of Edwards involves an unnamed attorney sanctioned by the court.
  • The attorney cited hallucinated AI-generated case law in legal submissions.
  • The court imposed a monetary sanction of $15,000.
  • The ruling was issued by the Illinois Appellate Court, Second District.
  • Reported by Hicks Johnson on September 1, 2026, highlighting regulatory oversight.
Outcome unclear
An attorney for State Farm apologized to LA Superior Court Judge Elizabeth Bradley after submitting motions in limine containing fabricated cases.
State Farm Insurance Company litigation · Los Angeles County Superior Court · CA
dailyjournal.com ↗
The file →
  • State Farm litigation involving home fire coverage in Carson
  • An attorney submitted motions in limine rife with fabricated cases
  • The attorney apologized to the court for the AI misuse
  • Los Angeles County Superior Court under Judge Elizabeth Bradley
  • The matter involved motions in limine submitted for an October trial
Outcome unclear
Judge Loren L. Alikhan ordered attorney Don Quinn to explain three inaccurate brief citations and disclose if generative AI was used.
Garner v. Transit Employees Federal Credit Union · Don Quinn · U.S. District Court for the District of Columbia · DC
alabnews.com ↗
The file →
  • Attorney Don Quinn of Quinn Patton was ordered by the court to explain inaccurate citations in a job bias case.
  • A brief was filed containing at least three citations with language or findings not present in the actual court opinions.
  • No formal sanction was imposed yet; the court issued an order to show cause asking if generative AI was used.
  • The case took place in the US District Court for the District of Columbia before Judge Loren L. Alikhan.
  • The order required an explanation within 14 days following a Bloomberg Law report published in September 2026.
Outcome unclear
Pleadings contained AI-generated hallucinations and fabricated authorities, leading the court to reference its generative AI guidance.
VTB Bank PJSC v Kuanyshev & Others · DIFC Court
lawgratis.com ↗
The file →
  • VTB Bank PJSC v Kuanyshev & Others
  • Pleadings contained AI-generated arguments with numerous fabricated or incorrectly described authorities
  • Court identified hallucinations and cited existing guidance on generative AI usage
  • DIFC Court (DIFC CFI 121/2025)
  • Highlighted that plausible-looking legal reasoning from AI is not necessarily reliable
Filing dismissed
Defendants' AI-assisted amended defence contained false references, leading the court to strike out the pleadings and award consequential costs.
Klesta Eshja & Hair Creators Salon LLC v Salah Masri & Others · DIFC Court
lawgratis.com ↗
The file →
  • Klesta Eshja & Hair Creators Salon LLC v Salah Masri & Others
  • Defendants filed AI-assisted amended defence containing false references and misleading material
  • Court struck out the problematic pleadings and ordered consequential costs
  • DIFC Court (DIFC CFI 066/2024)
  • Established that litigants cannot avoid procedural responsibility due to AI generation
Reprimanded
Attorney used generative AI to file motions with fake cases, misstatements, and a fictitious jury instruction, resulting in fee forfeiture and mandatory CLE.
Dastou v. Holmes · Middlesex Superior Court · MA
“By submitting motions and briefs that contain hallucinations and misstatements of the law, the lawyer violates their professional obligations.”
masslegalresources.com ↗
The file →
  • Dastou v. Holmes involved an attorney using generative AI for filings.
  • Filings contained fake cases, wrong quotes, misstated holdings, and a fictitious jury instruction.
  • Court barred attorney from billing client for tainted work and ordered mandatory CLE.
  • Middlesex Superior Court, Massachusetts, presided over by Judge Keren Goldenberg.
  • Date: June 2025; court ruled lawyers have a duty of competence and candor.
Reprimanded
Attorney was publicly reprimanded by the Board of Bar Overseers after staff used an AI program to generate unverified citations in court filings.
Matter of Marullo · Marullo · Board of Bar Overseers · MA
masslegalresources.com ↗
The file →
  • Matter of Marullo involved attorney Marullo disciplined for unverified AI research.
  • Staff used an AI program for motion research without attorney verification.
  • Board of Bar Overseers issued a public reprimand for ethical violations.
  • Massachusetts Board of Bar Overseers state disciplinary proceeding.
  • Date: 2025; attorney violated rules on competence, diligence, and supervision.
Referred to the bar $10K
A solicitor and two barristers were referred to disciplinary regulators after AI-produced submissions and authorities contained fake and inaccurate citations.
Mertz & Mertz (No 3) [2025] FedCFamC1A 222 · Full Court of the Federal Circuit and Family Court of Australia
“the “extent and in what way it was used remains opaque, notwithstanding the written submissions of the solicitor responsible.””
aubreybrown.com.au ↗
The file →
  • Mertz & Mertz (No 3) [2025] FedCFamC1A 222 involved a solicitor and two barristers.
  • AI was used to prepare a Summary of Argument and List of Authorities with non-existent and inaccurate citations.
  • The court referred them to regulators and ordered $10,000 in costs against the solicitor.
  • Full Court of the Federal Circuit and Family Court of Australia; federal jurisdiction; location not stated.
  • The article says this was the first time an appellate court in Australia sanctioned practitioners for AI misuse.
Referred to the bar
A solicitor advocate filed AI-generated submissions containing false case citations and gave incorrect information to the court, resulting in a regulatory referral.
Tesar & Szep (No 3) [2026] FedCFamC1F 21 · Federal Circuit and Family Court of Australia
aubreybrown.com.au ↗
The file →
  • In Tesar & Szep (No 3), a solicitor advocate submitted AI-fabricated citations.
  • The solicitor provided false information about how the submissions were prepared.
  • The court referred the solicitor advocate to the Legal Services Commissioner.
  • Federal Circuit and Family Court of Australia handled the matter.
  • The solicitor was ordered to pay personal legal costs and barred from charging the client for that work.

Showing 1–10 of 851.

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