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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

Counts only incidents where the filing court or the reporting named the tool.

Showing 111–120 of 151 incidents involving ChatGPT. Clear filters

Referred to the bar ChatGPT 2025-10-06
A lawyer filed grounds of appeal with at least two non-existent authorities, and the judge ordered the solicitor to show cause why the matter should not be referred to the SRA.
AK v Secretary of State for the Home Department · Upper Tribunal
damiencharlotin.com ↗
The file →
  • AK v Secretary of State for the Home Department involved a lawyer's appeal grounds.
  • The false citations likely came from unchecked generative-AI drafting.
  • The judge directed the solicitor to show cause about an SRA referral.
  • Upper Tribunal, UK.
  • 6 October 2025; the page names ChatGPT as the AI tool.
Fined $5K ChatGPT 2025-10-01
Mr. Laprade filed proceedings with false AI-generated citations and other authorities, and the Superior Court of Quebec imposed a $5,000 penalty.
Specter Aviation Limited c. Laprade · Jean Laprade · Superior Court of Québec
“The Court therefore imposed a $5,000 sanction on the Defendant, both to punish his conduct and to deter similar behaviour in the future.”
gowlingwlg.com ↗
The file →
  • Specter Aviation Limited v. Laprade; Mr. Laprade was sanctioned
  • He filed proceedings with false citations, decisions, and references produced using AI
  • The court imposed a $5,000 penalty
  • Superior Court of Quebec, Quebec
  • October 1, 2025; the court said AI cannot justify inaccurate or fabricated documents
Caught, not sanctioned ChatGPT 2025-09-30
Jisuh Lee filed a factum with ChatGPT-generated fake cases and later admitted she misled the court about who prepared it; the court treated it as criminal contempt.
Ko v. Li · Jisuh Lee · Ontario Superior Court of Justice
““Delivering a factum containing non-existent legal submissions creates a serious risk of a miscarriage of justice.””
benmor.com ↗
The file →
  • Ko v. Li involved lawyer Jisuh Lee and a factum with fabricated authorities.
  • The article says she used ChatGPT and failed to verify the citations.
  • The court treated the matter as criminal contempt, with no sanction yet imposed on this page.
  • Ontario Superior Court of Justice in Ontario, Canada.
  • On 2025-09-30, Lee admitted she alone used ChatGPT and had lied about staff involvement.
Filing dismissed ChatGPT 2025-09-30
A relator disclosed an expert report with generative-AI hallucinations, and the federal judge dismissed the FCA suit after related sanctions motions were filed.
U.S. ex rel. Khoury v. Intermountain Healthcare Inc et al. · Gary Giampetruzzi, Jessica R. Montes and Vanna Mavromatis · U.S. District Court for the District of Utah · UT
paulhastings.com ↗
The file →
  • U.S. ex rel. Khoury v. Intermountain Healthcare Inc et al. involved relator-side counsel and an expert report.
  • The report contained generative AI hallucinations, including bogus deposition testimony and fictitious quotes from government manuals.
  • On 2025-09-30, the federal judge granted the United States’ motion to intervene and dismiss the case.
  • The case was dismissed with prejudice to the relator and without prejudice to the United States.
  • District of Utah; the article does not name the AI tool, but says the expert used a generative AI tool and the parties had motion practice over sanctions.
Filing dismissed ChatGPT 2025-09-25
Oready, LLC filed protest briefs with fabricated, mismatched, and misquoted GAO citations, and GAO dismissed the protests as an abuse of process.
Oready, LLC · Government Accountability Office
“Our decision here is not based on the use of AI as a method of research; it is based on the protester’s repeated reliance on non-existent citations or decisions without verifying their correctness and applicability to the arguments being presented.”
centrelawgroup.com ↗
The file →
  • Oready, LLC was dismissed after filing AI-tainted protest briefs.
  • The filings included fabricated GAO decisions, mismatched citations, and misquoted holdings.
  • GAO dismissed the protests as an abuse of process.
  • Government Accountability Office; federal procurement protest forum.
  • Sept. 25, 2025; GAO said the issue was unverified non-existent citations, not AI use itself.
Fined $2K ChatGPT 2025-09-23
Lawrence Chang filed a reconsideration motion with AI-generated bogus citations and the court struck the motion and sanctioned him.
Lawrence Chang · Lawrence Chang · 459th District Court in Travis County · TX
“The court finds “good cause supports the imposition of sanctions in order to deter such conduct in the future, which amounts to serious misconduct that threatens to impugn the integrity of the courts and the administration of justice,” Guerra Gamble said.”
news.bloomberglaw.com ↗
The file →
  • Lawrence Chang was sanctioned in a Texas state-court matter involving his motion for reconsideration.
  • He admitted using AI and not checking the accuracy of the citations it produced.
  • The court ordered him to pay $2,000 in attorneys’ fees and expenses and struck the reconsideration motion.
  • Judge Maya Guerra Gamble issued the order in Texas state court.
  • Chang said he pasted his draft into ChatGPT’s legal tool to improve his writing.
Referred to the bar ChatGPT 2025-09-18
Barrister Muhammad Mujeebur Rahman cited a non-existent case generated with ChatGPT and was referred to the Bar Standards Board.
Y (China) · Muhammad Mujeebur Rahman · Upper Tribunal (Immigration and Asylum Chamber)
“We do however conclude that this is a case where referral to a regulator, in this instance the BSB, is most definitely appropriate”
localgovernmentlawyer.co.uk ↗
The file →
  • Muhammad Mujeebur Rahman was the barrister referred to the BSB.
  • He filed an immigration appeal relying on the bogus case Y (China) generated with ChatGPT.
  • The Upper Tribunal referred him to the Bar Standards Board; no contempt or police action was taken.
  • The court was the Upper Tribunal (Immigration and Asylum Chamber) in the UK.
  • On 2025-09-18, judges said he had not ensured the accuracy of what was placed before the tribunal.
Fined $10K ChatGPT 2025-09-12
Amir Mostafavi filed appellate briefs with fabricated AI-generated citations and quotations, and the California Court of Appeal sanctioned him $10,000 and referred him to the state bar.
Noland v. Land of the Free, L.P. · Amir Mostafavi · California Court of Appeal · CA
“Nearly all of the legal quotations in plaintiff’s opening brief, and many of the quotations in plaintiff’s reply brief, are fabricated,”

Cases that don't exist

  • Schimmel v. Levin (2011) 195 Cal.App.4th 81
llms-for-lawyers.com ↗
The file →
  • Noland v. Land of the Free involving an appellate attorney.
  • Brief contained 21 fabricated quotations out of 23 using ChatGPT, Claude, Gemini, and Grok.
  • Fined $10,000 and referred to the State Bar; winning opponents denied fees for failing to report fakes.
  • California Court of Appeal (2d Dist., 114 Cal. App. 5th 426).
  • Dated September 12, 2025; established obligation for opposing parties to notify court of fakes.
Fined $13K ChatGPT 2025-09-12
A federal judge sanctioned Hagens Berman Sobol Shapiro, Robert Carey, and Celeste Boyd after briefs in an OnlyFans case contained AI-generated hallucinated citations.
N.Z. v. Fenix International Ltd. · Hagens Berman Sobol Shapiro; Robert Carey; Celeste Boyd · U.S. District Court for the Central District of California · CA
“He wrote that allowing revisions would unfairly burden defendants who had already responded, noting that the proposed corrections still contained errors.”
complex.com ↗
The file →
  • OnlyFans users v. Fenix International Ltd. involved Hagens Berman Sobol Shapiro, Robert Carey, and Celeste Boyd.
  • Four briefs reportedly contained fabricated or hallucinated legal citations generated through AI tools.
  • Judge Fred Slaughter imposed $10,000 on the firm and Carey, plus $3,000 on Boyd.
  • U.S. District Court for the Central District of California; Seattle-based firm; California federal case.
  • The article says Boyd used ChatGPT to draft and edit sections and failed to independently verify the output.
Fined ChatGPT 2025-08-28
A pro se plaintiff filed a brief citing a non-existent Third Circuit case generated by AI, and Judge Karoline Mehalchick sanctioned him.
Allbaugh v. Univ. of Scranton · U.S. District Court for the Middle District of Pennsylvania · PA
“Rule 11 does not prohibit the use of generative AI, however, it does require parties to verify that they are not submitting briefs to the Court which rely on fictitious cases.”

Cases that don't exist

  • Allbaugh v. Univ. of Scranton, 2025 WL 2484188
cgalaw.com ↗
The file →
  • Allbaugh v. Univ. of Scranton involved a pro se plaintiff sanctioned for an AI-generated fake citation.
  • The plaintiff cited a non-existent Third Circuit opinion in a brief.
  • Judge Karoline Mehalchick imposed sanctions for the misuse of AI and the false citation.
  • The case was in the U.S. District Court for the Middle District of Pennsylvania.
  • On 2025-08-28, the court said parties must verify briefs do not rely on fictitious cases.
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