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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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151
Incidents tracked
26
Incidents in 2026
$542,786
In fines, where reported
50 of 151 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 60 of 151 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 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 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 53 Caught, not sanctioned 32 Warned 19 Referred to the bar 17 Reprimanded 13 Filing dismissed 10 Outcome unclear 6 Suspension 1

Showing 91–100 of 151 incidents involving ChatGPT. Clear filters

Filing dismissed ChatGPT 2026-02-06
Kenosha County Judge David Hughes sanctioned DA Xavier Solis and dismissed two criminal cases after Solis filed a response containing hallucinated AI case citations.
State v. Solis · Xavier Solis · Kenosha County Circuit Court · WI
“Hughes struck Solis’ written response after finding it used AI without disclosure and relied on “hallucinated,” false legal citations.”
yahoo.com ↗
The file →
  • Kenosha County DA Xavier Solis was sanctioned by Judge David Hughes.
  • Solis filed a brief riddled with hallucinated and bogus AI-generated case citations.
  • The court sanctioned Solis and dismissed two open criminal cases.
  • The proceedings occurred in Kenosha County Circuit Court, Wisconsin.
  • The sanction occurred in February after defense attorneys flagged fake citations in a motion reply.
Filing dismissed ChatGPT 2026-02-05
Defense counsel filed a motion-to-dismiss brief with false citations, then repeated the errors after a sanctions order to show cause; the court struck the filings and entered default judgment.
Flycatcher Corp. Ltd. v. Affable Ave. LLC · Steven A. Feldman · U.S. District Court for the Southern District of New York · NY
“Only 14 out of 60 cases were hallucinations.”

Cases that don't exist

  • 2022 WL 4637582
  • 2024 LEXIS 2847243
nysba.org ↗
The file →
  • Flycatcher v. Affable Avenue involving attorney Steven A. Feldman
  • Repeatedly submitted AI-generated fake citations and false quotes in bad faith
  • Briefs struck and default judgment entered against client
  • U.S. District Court for the Southern District of New York
  • Decided February 5, 2026; tools used included NotebookLM, vLex, and Paxton AI
Fined $12K ChatGPT 2026-02-02
Lawyers filed briefs with ChatGPT-hallucinated citations and quotations, and Judge Julie A. Robinson publicly admonished and sanctioned them.
Lexos Media IP, LLC v. Overstock.com, Inc. · Sandeep Seth; Kenneth Kula; Christopher Joe; Michael Doell; David Cooper · D. Kan. · KS
“the Rule 11 duty is “nondelegable.””
yahoo.com ↗
The file →
  • Attorneys Sandeep Seth, Kenneth P. Kula, Christopher M. Joe, and David R. Cooper sanctioned
  • Submitted nonexistent citations, fabricated quotations, and misrepresented decisions using ChatGPT
  • Sandeep Seth fined $5,000; Kula and Joe fined $3,000 each; Cooper fined $1,000 (total $12,000)
  • U.S. District Court for the District of Kansas under Judge Julie A. Robinson
  • Order issued February 2, 2026; Seth had his permission to appear revoked
Fined $1K ChatGPT 2026-02-01
A New Orleans court fined John Walker $1,000 after his LSU Health Foundation brief contained at least 11 fabricated or mischaracterized citations.
John Walker · John Walker · New Orleans · LA
““To this day it blows my mind it has that capability,””
developmentcorporate.com ↗
The file →
  • John Walker was sanctioned over an LSU Health Foundation brief.
  • The brief contained at least 11 fabricated or mischaracterized citations.
  • The court imposed a $1,000 fine.
  • New Orleans, Louisiana state court.
  • February 2026; Walker used both ChatGPT and Westlaw Precision AI.
Warned ChatGPT 2026-01-29
The appellant used ChatGPT to draft legal submissions and cited cases the tribunal could not locate; the tribunal refused his application and noted possible referral if he were registered.
Folarin v The Immigration Services Commissioner [2026] UKFTT 135 · UK First-tier Tribunal
““This would have had the effect of misleading the Tribunal had the Tribunal not challenged the point.””
naturalandartificiallaw.com ↗
The file →
  • Folarin v The Immigration Services Commissioner; the appellant's submissions
  • He used ChatGPT and other AI tools to find and summarize cases, some of which could not be located
  • No formal sanction, but the tribunal found he was not fit to provide immigration advice
  • UK First-tier Tribunal
  • 2026; tribunal stressed that false citations could mislead and that a future regulator referral was possible
Warned ChatGPT 2026-01-22
A lawyer used ChatGPT to generate fabricated case citations and was ordered by the court to inform their client and staff of the errors.
That Xiong v. Minga Wofford (1) · E.D. California · CA
damiencharlotin.com ↗
The file →
  • That Xiong v. Minga Wofford (1)
  • Lawyer used ChatGPT to generate fabricated case law citations.
  • Ordered to inform client and staff of errors.
  • U.S. District Court for the Eastern District of California
  • Decided January 22, 2026; ChatGPT explicitly cited as the tool used.
Fined $3K ChatGPT 2025-12-12
Co-counsel Celeste Boyd used ChatGPT to draft and edit portions of briefs in an OnlyFans-related case and was sanctioned $3,000 for failing to verify them.
Celeste Boyd · Celeste Boyd · U.S. District Court for the Central District of California · CA
“The judge additionally imposed a $3,000 sanction on co-counsel Celeste Boyd, who he said used ChatGPT to draft and edit portions of the briefs but failed to verify the material, Reuters also reports.”
abajournal.com ↗
The file →
  • Celeste Boyd was sanctioned as co-counsel in the OnlyFans case.
  • She used ChatGPT to draft and edit portions of briefs that contained hallucinated material.
  • The court imposed a $3,000 sanction on Boyd.
  • U.S. District Court for the Central District of California; Judge Fred Slaughter; California.
  • The article says she failed to verify the material before filing.
Caught, not sanctioned ChatGPT 2025-12-10
A pro se claimant used ChatGPT to generate fabricated case law, and the tribunal awarded a preparation time order of £2,178 stayed pending appeal.
Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy · Employment Tribunals (Leeds)
damiencharlotin.com ↗
The file →
  • Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy involved AI-generated citations.
  • ChatGPT generated fabricated case law in the pleadings.
  • The tribunal awarded a preparation time order of £2,178, stayed pending EAT appeal.
  • Employment Tribunals (Leeds), UK.
  • 10 December 2025; the page says the payment was stayed pending appeal.
Fined $60K ChatGPT 2025-12-05
An Illinois circuit court sanctioned a law firm $50,000 and an individual attorney another $10,000 for including false case citations and quotations in post-trial submissions, which the court characterized as a “serious failure” of the attorneys’ obligation to present truthful, accurate information.
Jordan v. Chi. Hous. Auth., No. 2022 L 000095 · Chicago Housing Authority's counsel · Cook County Circuit Court · IL
“The Court further emphasized its focus was “not on the misuse of artificial intelligence to conduct unreliable legal research and drafting,” but “the inexcusable submission of false authority and factual arguments to the Court, the subsequent misrepresentations about the extent of the improper conduct, and the failure to take prompt responsibility for errors once discovered.””

Cases that don't exist

  • Mack v. Anderson
klemchuk.com ↗
The file →
  • A law firm and an individual attorney were sanctioned in Jordan v. Chi. Hous. Auth.
  • They included 14 instances of non-existent quotes and fabricated holdings in post-trial submissions, generated using AI.
  • The sanction was a monetary fine totaling $60,000 ($50,000 for the firm and $10,000 for the attorney).
  • The sanction was issued by an Illinois Circuit Court.
  • The incident date was December 5, 2025, and the court emphasized that the obligations of officials of the court precede electronic research and artificial intelligence.
Referred to the bar ChatGPT 2025-12-04
Jisuh Lee filed a factum with hallucinated case law and allegedly lied about using ChatGPT; the court referred the matter for criminal contempt proceedings.
Ko v. Li · Jisuh Lee of ML Lawyers · Ontario Superior Court of Justice
““This is a very unusual case and one that may resonate throughout the administration of justice.””
regulayer.com ↗
The file →
  • Ko v. Li involved Jisuh Lee of ML Lawyers in an estate matter.
  • She filed a factum containing AI-hallucinated case law and later admitted using ChatGPT.
  • The court referred the contempt matter to Ontario’s attorney general; no amount was ordered.
  • Ontario Superior Court of Justice in Ontario, Canada.
  • Dec. 4 order; Justice Frederick Myers said it was a very unusual case.
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