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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 121–125 of 125 incidents. Clear filters

Warned 2024-08-12
A lawyer cited non-existent cases in written submissions, and the Board disregarded the false citations with no other consequence noted.
Industria de Diseño Textil, S.A. v. Sara Ghassai · Trademarks Opposition Board
“Whether accidental or deliberate, reliance on false citations is a serious matter [see Zhang v Chen, 2024 BCSC 285].”

Cases that don't exist

  • Vivat Holdings Ltd v Menasha Canada Ltd, 2001 FCA 278
  • M & M Meats Shops Ltd v M & M Products Inc, 2000 FCT 396
  • Molson Breweries v John Labatt Ltd, [2000] 3 SCR 890

+1 more

clia.ca ↗
The file →
  • Industria de Diseño Textil, S.A. v Sara Ghassi involved a lawyer citing cases that did not exist.
  • The Board disregarded the fake cases and noted no other consequences.
  • No sanction was imposed beyond disregarding the citations.
  • Trademarks Opposition Board, Canada.
  • 2024 TMOB 150; the Board mentioned possible generative AI but named no tool.
Warned ChatGPT 2023-08-22
The Delhi High Court warned that ChatGPT output cannot be the basis of adjudication and cautioned against fictional case laws and imaginative data.
Christian Louboutin SAS v. M/s The Shoe Boutique-Shutiq · Delhi High Court · DL
“the responses generated by ChatGPT cannot be the basis of adjudication of legal or factual issues in a court of law.”
blog.ipleaders.in ↗
The file →
  • Christian Louboutin SAS v. M/s The Shoe Boutique-Shutiq
  • A party had leaned on ChatGPT in a trademark dispute
  • The court issued a warning, not a money sanction
  • Delhi High Court, Delhi
  • 22 Aug 2023; the court warned against fictional case laws
Warned ChatGPT 2023-06-22
Levidow, Levidow & Oberman P.C. filed a submission with fake citations, and the court warned of sanctions but did not impose one.
Moten v. Apfel · Levidow, Levidow & Oberman P.C · U.S. District Court for the Southern District of New York · NY
““The Court is deeply concerned that a lawyer would submit a brief with citations that do not exist.””

Cases that don't exist

  • Martinez v. Air Line Pilots Ass’n, 2021 WL 4314517
  • Moten v. Apfel, 2023 WL 4001202
podcasts.apple.com ↗
The file →
  • Moten v. Apfel against Levidow, Levidow & Oberman P.C.
  • A filing contained AI-fabricated legal citations
  • The court issued a warning rather than a sanction
  • U.S. District Court for the Southern District of New York, New York
  • The judge said the court was deeply concerned about nonexistent citations
Warned ChatGPT 2023-05-27
A lawyer submitted a filing with six non-existent cases invented by ChatGPT, and the judge called it absurd and considered sanctions.
A lawyer submitted a filing with six non-existent cases invented by ChatGPT · New York judge · NY
“The judge called it absurd and considered sanctions.”
verileges.nl ↗
The file →
  • A lawyer filed a New York submission with fabricated cases.
  • ChatGPT invented six non-existent cases in the filing.
  • The judge considered sanctions but the page does not say they were imposed.
  • New York.
  • 27 May 2023; the judge called it absurd.
Warned ChatGPT 2023-01-01
The page says this 2023 South African case dealt with fake case law produced by ChatGPT, and the judge was more forgiving and found no intent to mislead.
Parker v Forsyth NO and Others
““In this age of instant gratification, this incident serves as a timely reminder to, at least, the lawyers involved in this matter that when it comes to legal research, the efficiency of modern technology still needs to be infused with a dose of good old-fashioned independent reading. Courts expect lawyers to bring a legally-independent and questioning mind to bear on, especially, novel legal matters, and certainly not to merely repeat in parrot-fashion, the unverified research of a chatbot.””
legal500.com ↗
The file →
  • Parker v Forsyth is named as a 2023 South African case.
  • The page says fake case law was produced by ChatGPT.
  • The judge found no intent to mislead and was more forgiving.
  • The court and judge are not named on the page.
  • 2023; the page presents it as an earlier, less severe South African incident.
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