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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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865
Incidents tracked
270
Incidents in 2026
$2,461,870
In fines, where reported
215 of 865 report an amount

The curve

Incidents per month

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

May 2025 Oct 2026

Charting 451 of 865 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 147 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 ClearBrief 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 Harvey 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 253 Caught, not sanctioned 198 Warned 123 Referred to the bar 103 Reprimanded 86 Outcome unclear 58 Filing dismissed 41 Suspension 2 Upcoming sanction 1
Reprimanded ChatGPT
An Oklahoma Supreme Court reprimanded an attorney for submitting legal motions containing AI-generated fake case citations.
Lawrence Wheeler · Lawrence Wheeler · Oklahoma Supreme Court · OK
“the careless use of generative artificial intelligence … damages the integrity and credibility of the legal system.”

Cases that don't exist

  • Cummings v. Cimarron Elevator Co.
  • Hawkins v. Linhart
fox40.com ↗
The file →
  • An unnamed attorney was reprimanded by the Oklahoma Supreme Court.
  • The attorney submitted legal motions containing AI-generated fabrications.
  • The sanction imposed was a formal public reprimand.
  • The matter was handled by the Oklahoma Supreme Court.
  • The reprimand occurred in May (year not specified); the court warned AI misuse damages legal integrity.
Outcome unclear
A Douglas County district court sanctioned counsel in connection with unverified AI-generated legal authorities without an AI-specific rule.
Mundy v. Clickstop, Inc. · Douglas County District Court · NE
legalaigovernance.com ↗
The file →
  • Mundy v. Clickstop, Inc. involved AI-related filing misconduct.
  • Counsel submitted brief/filings without independent verification of AI content.
  • The court sanctioned counsel without relying on an AI-specific rule.
  • The case took place in Douglas County District Court, Nebraska.
  • Decided in 2025 under general professional conduct rules.
Caught, not sanctioned Harvey
Judge Arun Subramanian declined to sanction Foundation Media's counsel after unchecked AI-generated citations were submitted in a copyright case filing.
Hill v. Foundation Media LLC · Cynthia Arato · U.S. District Court for the Southern District of New York · NY
jdjournal.com ↗
The file →
  • Cynthia Arato of Shapiro Arato Bach represented Foundation Media LLC in Hill v. Foundation Media LLC.
  • Unchecked quotes and citations generated by an AI tool were included in a court filing against firm policy.
  • U.S. District Judge Arun Subramanian examined the issue but declined to impose sanctions after counsel apologized.
  • The matter took place in the U.S. District Court for the Southern District of New York.
  • The firm used AI tools from Harvey and subsequently implemented new safeguards to prevent future errors.
Fined $1K
The federal district court imposed a $1,000 sanction for submitting AI-hallucinated legal citations.
Gittemeier v. Liberty Mutual · U.S. District Court for the Eastern District of Missouri · MO
legalaigovernance.com ↗
The file →
  • Gittemeier v. Liberty Mutual involved AI hallucinated citations filed in federal court.
  • The court found counsel submitted fabricated legal citations.
  • The court imposed a $1,000 monetary sanction.
  • U.S. District Court, Eastern District of Missouri.
  • Decided in 2025.
Filing dismissed
The court rejected an extension for a late refugee appeal after finding the memorandum relied on AI-generated fictitious case citations and inaccurate arguments.
Washim Ahmed · Washim Ahmed / OWS Law · Federal Court of Canada
“Citing fake cases in court filings is an abuse of process and is tantamount to making a false statement to the Court.”
nationalpost.com ↗
The file →
  • Refugee claimants represented by attorney Washim Ahmed (OWS Law).
  • A memorandum of argument was submitted containing AI-generated fake citations and inaccurate legal precedents.
  • Justice Roger Lafrenère refused to exercise discretion to accept the late filing, effectively dismissing the motion.
  • Federal Court of Canada.
  • The court noted that indiscriminate AI use constitutes a pernicious threat to judicial integrity.
Outcome unclear
The Illinois Appellate Court sanctioned appellate counsel for submitting briefs containing hallucinated citations and false quotations.
In re Baby Boy · Illinois Appellate Court, Fourth District · IL
leyhane.blogspot.com ↗
The file →
  • In re Baby Boy, 2025 IL App (4th) 241427
  • Appellate counsel submitted briefs with hallucinated citations and nonexistent quotations.
  • The Appellate Court entered sanctions against appellate counsel.
  • Illinois Appellate Court, Fourth District (State of Illinois)
  • The citations and quotes used in the appellate brief did not exist in the cited cases or statutes.
Referred to the bar 2026-10-01
The BIA imposed a six-month reciprocal suspension on an attorney after he submitted a brief with hallucinated AI case citations and falsely attributed them to typographical errors.
Matter of Sethi · Mike Singh Sethi · Board of Immigration Appeals
novo-legal.com ↗
The file →
  • Matter of Sethi involved immigration attorney Mike Singh Sethi.
  • Sethi submitted a brief containing fake, AI-generated case citations and falsely claimed they were typographical errors.
  • The BIA imposed a six-month reciprocal suspension from practicing before the BIA, Immigration Courts, and DHS.
  • The proceeding was conducted before the Board of Immigration Appeals based on a Ninth Circuit suspension.
  • The decision issued on October 1, 2026, establishing that AI misuse does not excuse compliance with professional conduct rules.
Fined $5K
The court imposed $5,000 in sanctions against an attorney for submitting 23 fabricated authorities across five filings.
Deutsche Bank v. LeTennier · New York Appellate Division · NY
law.com ↗
The file →
  • In Deutsche Bank v. LeTennier, an attorney was sanctioned for submitting AI-fabricated authorities.
  • The filings contained 23 fabricated authorities across five separate submissions.
  • The court imposed $5,000 in monetary sanctions.
  • The ruling was issued by the New York Appellate Division.
  • The court applied a multi-factor framework to evaluate sanctions for AI-generated fabrications.
Outcome unclear
Submission of nonexistent quotations in a filing implicated Rule 11(b)(2) and professional conduct rules on candor.
N-Bar Trade, Inc. v. Amazon.com Services LLC · U.S. District Court for the District of Columbia · DC
holonlaw.com ↗
The file →
  • N-Bar Trade, Inc. v. Amazon.com Services LLC involved fake quotations in court papers
  • The filing contained nonexistent quotations generated by AI technology
  • The court found the conduct implicated Rule 11(b)(2) and Rule 3.3(a)(1) duties of candor
  • Decided in the U.S. District Court for the District of Columbia
  • Decided in 2025 and reported at 807 F. Supp. 3d 11
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
news.bloomberglaw.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.

Showing 1–10 of 865.

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