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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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858
Incidents tracked
265
Incidents in 2026
$2,417,608
In fines, where reported
214 of 858 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 450 of 858 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 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
Caught, not sanctioned
The trial court order in Payne v State contained several AI-generated citations that did not exist or did not support the arguments, and the Georgia Supreme Court vacated it.
Payne v State · Supreme Court of Georgia · GA
“The state justices urged trial judges to examine proposed court orders “with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used”.”
thedailystar.net ↗
The file →
  • Payne v State involved a trial court order with bogus citations.
  • The order contained several legal citations that did not exist or did not support the arguments.
  • The Georgia Supreme Court vacated the order; no lawyer sanction amount was stated.
  • Supreme Court of Georgia; Georgia state court.
  • The page says the draft was prepared by the prosecutor with the aid of AI tools.
Referred to the bar 2026-08-12
An attorney was referred to the state bar after filing a certiorari petition containing fake AI-generated citations and claiming he accidentally submitted the wrong draft.
JMORR Properties, LLC v. Artist Alley Townhomes, LLC · Barry M. Leff · District Court of Appeal of the State of Florida, Fourth District · FL
“Counsel’s explanation that he mistakenly submitted the wrong draft of the petition does not excuse the failure to verify the accuracy of all citations in his filing.”
ediscoveryllc.com ↗
The file →
  • Barry M. Leff represented petitioner JMOR Properties, LLC in Florida state appellate court.
  • Leff submitted an AI-drafted certiorari petition containing false citations and non-existent case authority.
  • The court imposed a non-monetary sanction referring Leff to the Florida Bar for disciplinary proceedings.
  • The decision was issued by Florida's Fourth District Court of Appeal.
  • On August 12, 2026, the court held that inadvertently filing an unverified draft does not excuse the failure to verify citations.
Reprimanded 2026-08-10
A pro se contractor cited four fictitious AI-generated cases in its summary judgment motion; the Board struck those citations and imposed sanctions.
Appeal of PDO Ahuska Joint Venture LLC, ASBCA No. 64164 · Robert M. Pastorelli · Armed Services Board of Contract Appeals
pubkgroup.com ↗
The file →
  • Robert M. Pastorelli, representing PDO Ahuska Joint Venture LLC, was sanctioned.
  • He cited four fictitious AI-generated cases in a summary judgment motion.
  • The Board imposed a limited sanction by striking the fake citations.
  • The incident occurred at the Armed Services Board of Contract Appeals, a federal court.
  • The sanction was imposed on August 10, 2026, due to the 'blatant disregard' of the contractor's obligation to verify cases.
Warned Lexis+ AI 2026-08-07
Counsel filed briefs with fabricated quotations, said she used LexisNexis brief analysis for citation checking, and the court discharged the show-cause order but warned of future sanctions.
Smith v. Polk Co. · U.S. District Court for the Western District of North Carolina · NC
“The Court is deeply troubled by the errors previously identified in the Plaintiff’s filings, and counsel’s letter does little to allay the Court’s concerns.”
ediscoveryllc.com ↗
The file →
  • Smith v. Polk Co. involved plaintiff's counsel and fabricated quotations in filings.
  • Counsel said she used LexisNexis brief analysis and denied AI research hallucinations.
  • The court discharged the show-cause order but warned similar future filings would be sanctioned.
  • U.S. District Court for the Western District of North Carolina, North Carolina.
  • Aug. 7, 2026; the court was troubled that counsel could not explain the origin of the fabricated quotations.
Caught, not sanctioned 2026-08-07
The court imposed no sanctions on an attorney whose filing contained a false case quote generated by implied AI use.
Brown v. Real Estate Capital of America et al. · SC New York · NY
damiencharlotin.com ↗
The file →
  • Brown v. Real Estate Capital of America et al. involved an unnamed lawyer.
  • The lawyer submitted a filing containing 1 false quote from case law.
  • The court imposed no sanctions.
  • New York State Supreme Court.
  • Order issued August 7, 2026; AI use was implied.
Reprimanded 2026-08-05
An attorney was admonished by the court after submitting filings with three fabricated case citations and a misrepresented case.
San Antonio Independent School District v. Laura Becerra (as Next Friend of J.C.) · CA Texas · TX
technewsreel.com ↗
The file →
  • San Antonio ISD v. Becerra involved an unnamed lawyer.
  • Filings contained 3 fabricated case citations and 1 misrepresented case.
  • The court issued an admonishment.
  • Texas Court of Appeals.
  • Order issued August 5, 2026; AI use was implied.
Fined $5K ChatGPT
Jan Tomasik and Daniel Mann filed a brief with bogus citations generated by ChatGPT, and Judge Hardy ordered them removed, referred to the Nevada bar, and fined.
Uprise · Jan Tomasik; Daniel Mann; Cozen O’Connor · Washoe County, Nev., District Court · NV
“This is larger than any of us,”
lawnext.com ↗
The file →
  • Uprise; Jan Tomasik, Daniel Mann, and Cozen O’Connor
  • They filed a brief with bogus legal references generated by ChatGPT.
  • Judge Hardy ordered removal, bar referral, and $2,500 fines each ($5,000 total), then suspended them.
  • Washoe County, Nevada, District Court in Washoe County, Nev.
  • Last May; Hardy said he wanted system improvement and redemption.

Showing 101–110 of 858.

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