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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 101–110 of 151 incidents involving ChatGPT. Clear filters

Caught, not sanctioned ChatGPT 2025-12-04
McGuire Woods filed a brief with fake citations, and the court sanctioned the lawyer and ordered the firm to explain itself.
Ringer v. Bank of America, N.A. · McGuire Woods LLP · U.S. District Court for the Northern District of Georgia · GA
“In other words, the Court must be concerned with the message sent to other lawyers, firms and non represented parties as to the consequences of cutting corners, by using tools such as ChatGPT or even AI modules offered by reputable legal research databases without adequate care, or otherwise failing to verify the accuracy of citations and assertions in legal filings.”
tcpaworld.com ↗
The file →
  • Ringer v. Bank of America; McGuire Woods LLP was involved.
  • A lawyer filed a brief containing a ton of fake cites.
  • The court sanctioned the lawyer and required the firm to explain itself.
  • U.S. District Court for the Northern District of Georgia.
  • Dec. 4, 2025; the court said careless citation errors must not be tolerated.
Referred to the bar ChatGPT 2025-11-27
A barrister used ChatGPT to draft appeal grounds with a false citation and the tribunal reported him to the Bar Standards Board but did not start contempt proceedings.
MS v Secretary of State for the Home Department · Upper Tribunal (Immigration and Asylum Chamber)
barcouncil.org.uk ↗
The file →
  • MS v Secretary of State for the Home Department involved a barrister before the Upper Tribunal.
  • He included a false citation and later used ChatGPT to draft the grounds of appeal.
  • The tribunal referred him to the Bar Standards Board but did not initiate contempt proceedings.
  • Court: Upper Tribunal (Immigration and Asylum Chamber), Bangladesh; [2025] UKUT 305 (IAC).
  • Date: 2025-11-27; he did not use Westlaw or Lexis Nexis to check the work.
Reprimanded ChatGPT 2025-11-21
Gordon Rees submitted filings with hallucinated AI citations; Judge Christopher L. Hawkins declined to sanction the firm but reprimanded former lawyer Cassie D. Preston.
In re Jackson Hospital & Clinic, Inc., et al. · Gordon Rees; Cassie Preston · U.S. Bankruptcy Court for the Middle District of Alabama · AL
“attorneys must not allow their personal feelings to cloud their professional judgment, and Ms. Preston crossed a line when she resorted to making use of arguments and authorities generated by artificial intelligence”
news.bloomberglaw.com ↗
The file →
  • Jackson Hosp. & Clinic Inc. and Cassie Preston were sanctioned in bankruptcy court.
  • She submitted filings with artificial-intelligence generated fake citations.
  • The court publicly reprimanded her and ordered disclosure/compliance steps, with no monetary amount stated.
  • US Bankruptcy Court for the Middle District of Alabama; Judge Christopher L. Hawkins.
  • Order dated 2025-11-21; the opinion also found misleading and fabricated citations.
Fined ChatGPT 2025-11-19
A lawyer was sanctioned with a 500 CAD penalty and denied identity anonymization after filing a ChatGPT-fabricated case citation.
Yuehong v. The Minister of Citizenship & Immigration · Federal Court
damiencharlotin.com ↗
The file →
  • Yuehong v. Minister of Citizenship & Immigration involved an unnamed counsel in Canada.
  • Counsel submitted a brief containing a fabricated case citation from ChatGPT.
  • Ordered to pay a monetary sanction of 500 CAD; court refused to anonymize lawyer's name.
  • Decided in the Federal Court of Canada.
  • Issued November 19, 2025, naming ChatGPT explicitly as the source.
Outcome unclear ChatGPT 2025-11-19
A lawyer relied on ChatGPT, resulting in fabricated legal citations and misrepresented case law in court.
ECLI:NL:RBNNE:2025:4814 · Rechtbank Noord-Nederland
damiencharlotin.com ↗
The file →
  • ECLI:NL:RBNNE:2025:4814 involved an unnamed attorney in the Netherlands.
  • The attorney used ChatGPT, leading to 1 fake case, 1 fake reference, and 1 misrepresented case.
  • No specific sanction outcome was specified in the entry.
  • Decided in the Rechtbank Noord-Nederland in the Netherlands.
  • Issued November 19, 2025; ChatGPT identified as the source.
Referred to the bar ChatGPT 2025-11-17
CLP filed judicial-review grounds with bogus authorities and the Upper Tribunal said the author and COLP should expect referral.
R (Munir) v SSHD · Mr. Zubair Rasheed of City Law Practice Solicitors · Upper Tribunal (Immigration and Asylum Chamber)
“It would be easy to think that this is a case about the naïve use of generative AI, but it is not merely about that; it is principally about supervision and the obligation to ensure that the tribunal is not misled.”
sra.org.uk ↗
The file →
  • R (Munir) v SSHD involved City Law Practice Solicitors and Advocates and Zubair Rasheed.
  • Judicial-review grounds were filed with bogus authorities and incorrect citations.
  • The Upper Tribunal said the conduct should ordinarily be referred to a regulator.
  • Upper Tribunal (IAC), United Kingdom; Judges Lindsley, Keith and Blundell.
  • 17 November 2025; the court stressed supervision failures and mentioned ChatGPT.
Filing dismissed ChatGPT 2025-11-14
A pro se filer used AI-generated citations in a bankruptcy filing; the court sanctioned her by dismissing the case without prejudice.
In re Cathleen Siebrecht · Cathleen Siebrecht · U.S. Bankruptcy Court, Eastern District of Virginia · VA
““The ‘AI-generated citations’ in the filing were ‘hallucinated’ and not supported by the law.””

Cases that don't exist

  • In re Zepeda, 2023 Bankr. LEXIS 1234
  • In re Jones, 2024 WL 1234567
calawyers.org ↗
The file →
  • In re Cathleen Siebrecht involved Cathleen Siebrecht, who filed a bankruptcy paper with AI-generated citations.
  • The filing contained hallucinated legal citations and the court found they were unsupported by law.
  • The court dismissed the case without prejudice.
  • It was in the U.S. Bankruptcy Court for the Eastern District of Virginia.
  • The order was entered on 2025-11-14, and the page says the citations were ChatGPT-generated.
Caught, not sanctioned ChatGPT 2025-11-10
Cal State filed a brief with faulty quotes and phantom quotations that an administrative law judge struck from the record.
California State University brief striking order · California State University · California Public Employment Relations Board · CA
“while “there is no proof that AI was, in fact the author” of a Cal State brief, the document “bears all the hallmarks of the hallucinations associated with AI-generated texts” and contains a series of misquotes Cal State failed to explain.”

Cases that don't exist

  • Marshall v. Regis Educational Corporation
laist.com ↗
The file →
  • California State University was the party whose brief was struck.
  • The brief contained faulty quotes and phantom quotations from a 1981 decision.
  • Administrative Law Judge Bernhard Rohrbacher ordered the filing struck from the record.
  • The matter was before the California Public Employment Relations Board in California.
  • CSU later acknowledged the brief had been written with AI assistance.
Referred to the bar ChatGPT 2025-10-29
Adam Hyman filed an AI-generated divorce brief with fake cases and misquotes, and the Appellate Court of Maryland referred him to the Attorney Grievance Commission.
Mezu v. Mezu · Adam Hyman · Appellate Court of Maryland · MD
“The failure to use AI responsibly in legal research raises ethical issues and can result in sanctions when used improperly. It is unquestionably improper for an attorney to submit a brief with fake cases generated by AI.”
thedailyrecord.com ↗
The file →
  • Adam Hyman was the lawyer referred to the Attorney Grievance Commission.
  • He submitted a divorce brief prepared with ChatGPT that contained fake cases and misquotes.
  • The court imposed a referral to the AGC, with no dollar amount stated.
  • The incident was in the Appellate Court of Maryland in Maryland.
  • The opinion was issued Oct. 29, 2025; Judge Kathryn Graeff said attorneys must verify cited authority.
Fined $1K ChatGPT 2025-10-23
Counsel filed opposition papers with AI-generated false Louisiana case citations; the trial court sanctioned her and the appellate court affirmed.
In re: Sanctions Order of KENNEY (2025) · Connie P. Trieu · Court of Appeal of Louisiana, Fifth Circuit · LA
“Plaintiff's counsel submitted legal authority and citations generated by “A.I.” software without verifying their authenticity.”

Cases that don't exist

  • Burns v. State, 813 So.2d 574
  • Smith v. Christus St. Patrick Hosp., 20-306 (La. App. 3 Cir. 11/3/20), 308 So.3d 1216
  • Doe v. Southwest Louisiana Hosp. Ass'n, 02-180 (La. App. 3 Cir. 7/10/02), 833 So.2d 1136
caselaw.findlaw.com ↗
The file →
  • In re: Sanctions Order of KENNEY (2025) sanctioned Connie P. Trieu.
  • She filed pleadings containing three fabricated Louisiana citations and other citation errors.
  • The trial court ordered $1,368 in attorney's fees plus costs.
  • Court of Appeal of Louisiana, Fifth Circuit, in Louisiana.
  • Decided October 23, 2025; the opinion says the citations were generated by AI and notes ChatGPT and Microsoft Copilot were used.
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