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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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251
Incidents tracked
81
Incidents in 2026
$1,813,310
In fines, where reported
186 of 251 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 139 of 251 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 53 Claude 4 Lexis+ AI 4 Westlaw Precision 4 CoCounsel 3 Copilot 2 AI-assisted legal software 1 Archie 1 ChatOn 1 ClearBrief 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 Gemini 1 Ghostwriter Legal 1 Google AI 1 Google Scholar 1 Grok 1 Irys 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

Showing 111–120 of 251 incidents. Clear filters

Fined $500 2026-07-30
Dean Kajioka filed a habeas reply with a hallucinated citation; Judge Monica Trujillo struck the document and imposed $500 in sanctions.
Robert Schwieger · Dean Kajioka · Regional Justice Center; District Judge Monica Trujillo · NV
“AI was misused”

Cases that don't exist

  • Evans v. State, 123 Nev. 117, 159 P.3d 438 (2007)
govtech.com ↗
The file →
  • Dean Kajioka represented Robert Schwieger in the Piero’s bombing case.
  • Prosecutors said his reply brief was largely created using AI and cited a nonexistent case.
  • They sought sanctions and to strike the brief.
  • The matter was in Nevada state court before District Judge Monica Trujillo.
  • The article says the filing cited 'Evans v. State, 123 Nev. 117, 159 P.3d 438 (2007),' which prosecutors could not find.
Fined $15K ChatGPT 2026-07-28
Chicago lawyer Mason Cole was fined $15,000 and referred to state disciplinary authorities for filing appellate briefs containing 10 AI-fabricated or misquoted citations.
Scott v. Illinois Human Rights Commission · Mason Cole of Cole Sadkin · Illinois Appellate Court for the First District · IL
“We do not know why attorney Cole feels compelled to rush out obviously flawed filings, but this must stop.”
reason.com ↗
The file →
  • Attorney Mason Cole in Scott v. Ill. Hum. Rts. Comm'n was sanctioned.
  • Cole filed briefs with 10 false citations, including fabricated statutory language and nonexistent case law, after using ChatGPT.
  • The court imposed a monetary fine of $15,000 ($1,500 per false citation) and referred him to the ARDC.
  • The incident occurred in the Appellate Court, First District, Illinois.
  • The sanction was issued on August 13, 2026, with the judge noting that AI-hallucinated citations are no different than false citations created by an attorney's own imagination.
Fined 2026-07-15
A pro se appellant filed a brief with six deficient citations, including two non-existent AI-generated cases, and was ordered to pay a portion of his sister's legal fees.
Estate of Acciavatti, Dineen/Shibata v. Kotchka · Jeffrey Kotchka · Arizona Court of Appeals · AZ
“Litigants who file documents with the courts remain directly and personally responsible for the content, accuracy, and quality of legal filings submitted to all courts.”
jshfirm.com ↗
The file →
  • Pro se appellant Jeffrey Kotchka was sanctioned in Estate of Acciavatti, Dineen/Shibata v. Kotchka
  • Kotchka used AI to write his appellate brief, which included two completely non-existent case citations
  • The court imposed a monetary sanction requiring him to pay a portion of his sister's legal fees
  • Arizona Court of Appeals (State jurisdiction, Arizona)
  • Decision issued on July 15, 2026; Kotchka admitted using AI without consulting attorneys or standard legal tools
Fined $30K Westlaw Precision 2026-07-14
Attorney Gregory W. Mitchell filed Motions to Quash containing fabricated citations and was sanctioned $29,877 jointly and severally with creditors.
In re Rosslyn2016, LLC and Texas Esencia 2019 LLC · Gregory W. Mitchell · U.S. Bankruptcy Court for the Southern District of Texas · TX
“Mitchell's suggestion that the "Precision" version of Westlaw, which is a generative AI tool offered by Westlaw, should be given different treatment from non-legal AI tools demonstrates Mitchell's disregard for the General Orders of the Southern District of Texas.”
nydailyrecord.com ↗
The file →
  • Rosslyn2016, LLC and Texas Esencia 2019 LLC; attorney Gregory W. Mitchell sanctioned.
  • Submitted Motions to Quash containing fabricated quotations and nonexistent legal citations without verifying them.
  • Ordered to pay $29,877 in attorneys' fees and costs jointly and severally, plus complete 6 hours of CLE on generative AI.
  • U.S. Bankruptcy Court for the Southern District of Texas.
  • Order issued July 14, 2026; Mitchell claimed citations came from a template and noted using Westlaw AI tools.
Fined $10K Lexis+ AI 2026-07-02
An AI-assisted brief filed in a civil appeal contained fabricated citations and inaccurate quotations, and the court imposed $10,500 in sanctions on the attorney and his firm.
Landberg v. City of New York · Michael Sanders; Law Offices of Michael S. Lamonsoff PLLC · Appellate Division of the New York State Supreme Court, Second Department · NY
“"It's striking, concerning, disappointing, and saddening to think that members of the bar would forward cases to a court that don't exist, and to think that the lawyers on the other side of that didn’t read it for whatever reason, didn’t check it."”
forchellilaw.com ↗
The file →
  • Michael Sanders and Law Offices of Michael S. Lamonsoff PLLC were sanctioned.
  • Sanders filed a brief containing fake citations and fake quotations from AI-assisted research.
  • The court imposed $10,500 total: $8,000 on Sanders and $2,500 on the firm.
  • Appellate Division of state Supreme Court, Second Department, New York.
  • June 26, 2026 article; Sanders said the citations came from hallucinated AI and he failed to verify them.
Fined $2K 2026-06-22
A Pennsylvania plaintiffs lawyer filed briefs with AI-generated hallucinated citations and was fined $1,500 and suspended from the court for six months.
Brian Kent · Brian Kent · U.S. District Court in Pennsylvania · PA
law.com ↗
The file →
  • Brian Kent, a Pennsylvania plaintiffs attorney, was sanctioned by a federal court in Pennsylvania.
  • He filed briefs containing AI-generated hallucinated citations.
  • The court ordered a $1,500 penalty and a six-month suspension.
  • The matter was in federal court in Pennsylvania.
  • The article says the errors were inadvertent and tool-driven.
Fined $31K Grok 2026-06-17
Shahryar Mazaheri used AI to draft court filings containing fake and irrelevant citations, and the tribunal ordered him to pay $31,150 in costs.
Mazaheri v Law Society of Ontario · Shahryar Mazaheri · Law Society Tribunal of Ontario · ON
“"But unlike a human, a large language model does not appreciate nuance or exercise judgment or use a moral compass when writing. It just does calculations, and then puts words in the order dictated by statistical probabilities. The calculations are impressive – large volumes of authoritative-sounding text are generated in seconds or minutes. But they are just calculations. And the product only reads or sounds like text written by humans. It isn't the same."”
damiencharlotin.com ↗
The file →
  • Mazaheri v. Law Society of Ontario involved Shahryar Mazaheri.
  • He used AI to prepare a factum, supplementary factum, affidavit, and supplementary affidavit without checking the output.
  • The tribunal ordered costs of $31,150 to the Law Society of Ontario.
  • The decision was by the Law Society Tribunal in Ontario, Canada.
  • The article says the AI output included citations to cases that don’t exist and real cases irrelevant to the points made.
Fined 2026-06-17
An attorney filed multiple court documents, including an appellate brief, containing fabricated citations, leading the Michigan Court of Appeals to issue an opinion holding that an apology is not a cure and sanctioning the attorney.
Joyce Barber v. Lawrence J. Morawa, MD · Ronnie Cromer Jr · Court of Appeals of Michigan · MI
damiencharlotin.com ↗
The file →
  • In Barber v Morawa, an unnamed attorney was sanctioned.
  • The attorney filed multiple documents with fabricated citations and delayed correcting them for eight months.
  • The sanction was a monetary fine paid personally by counsel, and the matter was referred to the Attorney Grievance Commission.
  • The Michigan Court of Appeals issued the sanction.
  • The incident date is June 17, 2026, and the court emphasized the objective reasonable-inquiry standard, making good faith irrelevant.
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