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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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125
Incidents tracked
50
Incidents in 2026
$4,000
In fines, where reported
1 of 125 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 73 of 125 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 19 Copilot 5 AI-assisted legal software 2 ChatGPT-4o 1 Claude 1 CoCounsel 1 Lexis+ AI 1 Strongsuit 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 125 Referred to the bar 101 Reprimanded 86 Outcome unclear 56 Filing dismissed 37 Suspension 2 Upcoming sanction 1

Showing 91–100 of 125 incidents. Clear filters

Warned $4K 2026-01-28
Jeffrey Goldin signed a motion to dismiss with AI-generated false citations; Judge Kearney declined a monetary sanction but ordered a non-monetary corrective distribution.
Lifetime Well LLC v. IBSPOT.Com, Inc. · Jeffrey Goldin · U.S. District Court for the Eastern District of Pennsylvania · PA
“the burden should not have fallen on us to expend judicial resources identifying blatantly false cites.”
ediscoverytoday.com ↗
The file →
  • IBSpot.com motion to dismiss filed by Jeffrey Goldin and Yen-Yi Anderson
  • The filing contained AI-generated false citations that Goldin did not catch before filing
  • Goldin received no monetary sanction but had to circulate the decision and his AI policy
  • U.S. District Court in Pennsylvania, Judge Mark A. Kearney
  • 2026-01-28; Goldin had completed CLE and other remedial steps
Warned 2026-01-28
The court warned that filings with AI-fabricated or incorrect citations may be struck and may draw sanctions, referral, disqualification, filing restrictions, or dismissal.
AI-assisted filings with fabricated or incorrect legal citations · United States District Court for the District of Kansas · KS
“Litigants are therefore responsible for reviewing and verifying the accuracy of all content filed with this court that was drafted or assisted by an AI tool.”
josephhollander.com ↗
The file →
  • SO 26-01 was issued by the District of Kansas court.
  • It addressed filings containing false statements and fabricated or incorrect legal citations.
  • The order did not impose a monetary sanction; it warned of possible sanctions.
  • United States District Court for the District of Kansas, Kansas.
  • 2026-01-28; signed by Chief Judge John W. Broomes and warned about AI-assisted filings.
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.
Warned AI-assisted legal software 2026-01-19
The Court admonished the pro se litigant for filings with hallucinated case law and false legal propositions attributed to undeclared generative AI use.
Amit Arora v. Canadian National Railway · Amit Arora · Federal Court

Cases that don't exist

  • Manitoba v. CHRC, 2016 FC 836
  • CP Rail v. Canada (AG), 2015 FC 1348
aivortex.io ↗
The file →
  • Amit Arora v. Canadian National Railway; Amit Arora was the pro se litigant.
  • He filed written representations containing hallucinated case law and false legal propositions.
  • The Court issued a formal admonishment and dismissed the motion; costs were awarded to the respondent.
  • Federal Court; Canada.
  • Jan. 19, 2026; the Court attributed the errors to undeclared, unverified generative AI use.
Warned 2025-12-15
Garcia appealed with fabricated legal citations made by generative AI, and PERB affirmed dismissal but declined monetary sanctions.
Atwater Elementary Teachers Association, CTA/NEA (Garcia) · Christina Garcia · California Public Employment Relations Board · CA
perb.ca.gov ↗
The file →
  • Atwater Elementary Teachers Association, CTA/NEA (Garcia) and Christina Garcia
  • Garcia’s appeal contained fabricated legal citations created by generative AI tools
  • PERB affirmed dismissal and declined monetary sanctions
  • California Public Employment Relations Board, California
  • 2025-12-15; PERB warned that fabricated citations in filings will bring serious consequences
Warned Copilot 2025-12-11
Dana McClain filed a pleading with AI-generated citations that could not be verified, and the Arkansas Supreme Court issued a show-cause order.
Dana McClain · Dana McClain · Arkansas Supreme Court · AR
“In its order, the Supreme Court reminded attorneys they are responsible for the accuracy of all filings and warned that misuse of artificial intelligence in legal work could result in discipline, including substantial fines, suspension or loss of the privilege to practice law in Arkansas.”
ktlo.com ↗
The file →
  • Dana McClain was the Arkansas attorney involved.
  • She filed court documents containing AI-generated citations that could not be verified.
  • The Arkansas Supreme Court issued a show-cause order; the article does not report a monetary sanction.
  • Arkansas Supreme Court, Arkansas.
  • Dec. 11, 2025; she said she used Microsoft Office Copilot to draft the response and failed to verify the citations.
Warned 2025-11-21
A employer's lawyer submitted non-existent case citations in an arbitration proceeding, prompting a judicial warning from the tribunal.
Syndicat des travailleuses et travailleurs c. Centre L’Autre Maison inc. · Tribunal d'arbitrage (Québec)
damiencharlotin.com ↗
The file →
  • Syndicat des travailleuses v. Centre L'Autre Maison inc. involved an unnamed employer's lawyer.
  • The lawyer submitted non-existent jurisprudence (fabricated case law) in arbitration.
  • The tribunal issued a warning and criticized the conduct as reprehensible.
  • Decided by the Tribunal d'arbitrage (Québec) in Canada.
  • Issued on November 21, 2025; noted AI hallucinations waste time and increase costs.
Warned 2025-11-21
An attorney was issued a court warning after filing briefs containing five fabricated case citations and a fake legal norm.
Shields v. First Financial · Tennessee · TN
damiencharlotin.com ↗
The file →
  • Shields v. First Financial involved an unnamed lawyer submitting fabricated legal references.
  • The attorney submitted 5 fabricated cases and 1 fabricated legal norm.
  • The court issued a judicial warning to the attorney.
  • Decided in Tennessee state court.
  • Order issued on November 21, 2025; implied generative AI hallucination.
Warned 2025-11-19
A lawyer was warned and had parts of a brief struck for submitting two AI-fabricated case law citations.
0997510 BC Ltd. v. Area 15 · BC PAAB
damiencharlotin.com ↗
The file →
  • 0997510 BC Ltd. v. Area 15 involved an unnamed lawyer.
  • The lawyer cited two non-existent case law references created by AI.
  • The board issued a warning and struck the affected parts of the brief.
  • Decided by the British Columbia Property Assessment Appeal Board in Canada.
  • Issued November 19, 2025; unidentified AI tool.
Warned 2025-11-13
Parties filed AI-generated cost submissions with fake cases and bad hyperlinks, and the court ordered them to address the misuse.
X.L. v. Z.L. · Ontario Superior Court of Justice · ON

Cases that don't exist

  • Bank of Montreal v. Wilder, [1986] 2 S.C.R. 118
  • Gowling Lafleur Henderson LLP v. Shorter, 2011 ONSC 5840
  • Ontario Inc. v. Ranch Heating and Air conditioning (Barrie) Limited, 2012 ONSC 182
grllp.com ↗
The file →
  • X.L. v. Z.L. involved respondents S and Y, and maybe Z.L.
  • Their submissions used AI and cited fake cases or hyperlinks that did not support the propositions.
  • The court ordered them to address the AI-generated submissions; the article says cost sanctions were still awaited.
  • Ontario Superior Court of Justice, Ontario.
  • November 13, 2025; the practice directions say AI misuse can lead to reprimand, costs, fines, dismissal, and referral.
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