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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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199
Incidents tracked
40
Incidents in 2026
$11,578
In fines, where reported
3 of 199 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 75 of 199 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 32 Gemini 4 Claude 2 Perplexity AI 2 AI Overviews 1 ChatGPT-4o 1 ChatOn 1 Eve 1 Grammarly 1 MX2.law 1 OpenCase 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 131–140 of 199 incidents. Clear filters

Caught, not sanctioned 2026-04-29
A pro se plaintiff filed a brief with fabricated citations while seeking leave to amend; the court struck the motion for AI errors and procedural violations.
Adams v. Kiewit Infrastructure West Company · D. Ariz. · AZ
“While the use of [generative AI] is not necessarily problematic, the failure to confirm the accuracy of the filing is. ... Plaintiff’s pro se status does not relieve her of this requirement.”
fisherphillips.com ↗
The file →
  • Adams v. Kiewit Infrastructure West Company involved a pro se plaintiff.
  • Her brief included at least two fabricated case citations and an irrelevant real case.
  • The court struck the motion from the record.
  • D. Ariz., federal court in Arizona.
  • April 29, 2026; the court said the filing was not verified for accuracy.
Caught, not sanctioned 2026-04-29
A self-represented appellant cited two nonexistent cases and one irrelevant real case; the court treated all issues as waived and affirmed summary judgment.
Nisland Asset Investment, LLC v. Gericke · Iowa Ct. App. · IA
“We do not have a double standard for those represented by counsel and those who are unrepresented – we expect all to follow our procedures. … We have repeatedly stressed that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.”
fisherphillips.com ↗
The file →
  • Nisland Asset Investment, LLC v. Gericke involved a self-represented homeowner.
  • Her appellate brief cited two nonexistent cases and one irrelevant real case.
  • The court deemed every issue waived and affirmed summary judgment.
  • Iowa Court of Appeals, state court in Iowa.
  • April 29, 2026; the court emphasized independent verification of AI-assisted sources.
Caught, not sanctioned ChatGPT 2026-04-18
Sullivan & Cromwell filed an emergency motion with AI hallucinations and inaccurate citations, then apologized and corrected the filing before any sanctions order.
In re Prince Global Holdings Limited, et al. · Sullivan & Cromwell LLP · U.S. Bankruptcy Court, Southern District of New York · NY
“"Hallucinations" are instances in which artificial intelligence tools fabricate case citations, misquote authorities, or generate non-existent legal sources,”
reuters.com ↗
The file →
  • Prince Global Holdings bankruptcy matter; Sullivan & Cromwell was the firm involved.
  • A filing contained inaccurate citations and other errors, including AI hallucinations.
  • No sanction is reported; the firm apologized and said it would correct the filing.
  • The matter was in Manhattan before Chief Judge Martin Glenn.
  • On 2025-04-18, partner Andrew Dietderich wrote the judge; the errors were caught by Boies Schiller Flexner.
Caught, not sanctioned 2026-04-13
Joanne Jones filed an appeal using undisclosed generative AI with incorrect citations and references; the Commission dismissed the appeal on jurisdictional grounds and did not take the matter further.
Sentinel Community Services Pty Ltd v Clark Chesaites · Ms Joanne Jones · NSW Personal Injury Commission
“the deployment of undisclosed generative AI has not affected or perverted the result of this application and for this Ms Jones and Sentinel should be grateful”
carternewell.com ↗
The file →
  • Sentinel Community Services Pty Ltd v Clark Chesaites involved Ms Joanne Jones.
  • Jones used undisclosed generative AI in appeal materials and submissions.
  • The Commission did not impose a sanction and dismissed the appeal on jurisdictional grounds.
  • NSW Personal Injury Commission, New South Wales.
  • 13 April 2026; the materials contained incorrect citations and misdated Barden v Walgett Shire Council.
Caught, not sanctioned OpenCase 2026-04-09
Counsel filed a brief with nonexistent authorities and fake quotations, and the court discharged the show-cause order without imposing sanctions.
Gamez v. County of Fresno · Kevin Little · U.S. District Court, Eastern District of California · CA
“the court accepted his explanation that he believed the AI tool had anti-hallucination protection”
law360.com ↗
The file →
  • In Gamez v. County of Fresno, an attorney narrowly avoided sanction.
  • An opposition brief contained nonexistent authority and fabricated quotations.
  • No sanction was imposed after a candid and detailed explanation.
  • The incident occurred in the U.S. District Court, E.D. Cal., with M.J. Grosjean.
  • On 2026-04-09, a paid generative AI tool was used, which the attorney believed had anti-hallucination protection.
Caught, not sanctioned $3K 2026-04-09
A brief produced using AI contained citations to nonexistent authorities and fictitious holdings, and the court addressed defendants' request to strike it.
Hulvat v. Gumina · Illinois Appellate Court, Third District · IL
“Robert’s reliance on fictitious authority is a pervasive, nascent, and very serious issue afflicting courts as the use and reliance on generative AI in preparing legal filings becomes more commonplace. … Robert’s self-represented status does not excuse his misuse of AI. … A monetary penalty in this context should impress upon all litigants the caution one must undertake when utilizing AI in brief preparation and the solemnity of filing documents before the court.”
ilcourtsaudio.blob.core.windows.net ↗
The file →
  • Hulvat v. Gumina involved a brief produced using AI.
  • The brief contained citations to nonexistent authorities and fictitious holdings.
  • The court considered defendants' request to strike the brief.
  • Illinois Appellate Court, Third District, Illinois.
  • The page does not name an attorney, firm, date, AI tool, or a sanction amount.
Caught, not sanctioned 2026-04-09
In a shareholder dispute, a lawyer cited non-existent case law and the Enterprise Chamber noted AI had “run amok”; the case ended in a settlement.
Lawyer blunders at Enterprise Chamber with fictional case law · Enterprise Chamber
“Judges spoke of AI that had “run amok”.”
verileges.nl ↗
The file →
  • A lawyer in a shareholder dispute was involved.
  • The lawyer cited non-existent case law and corrected filings produced new fictional ECLI numbers.
  • The case ended in a settlement and no sanction is stated.
  • Enterprise Chamber.
  • 9 April 2026; judges said AI had “run amok”.
Caught, not sanctioned 2026-04-06
A pro se plaintiff filed motions citing fabricated quotations and a nonexistent proposition; the court struck one motion and denied another.
Hardy v. Genesee County Community Action Resource Department, et al. · E.D. Mich. · MI
“Courts and opposing counsel are burdened by the careless use of AI by pro se filers.”
fisherphillips.com ↗
The file →
  • Hardy v. Genesee County Community Action Resource Department, et al. involved a pro se filer.
  • His motion to consolidate cited fabricated quotations from two real Sixth Circuit opinions.
  • The court struck the consolidation motion and denied the motion to compel.
  • E.D. Mich., federal court in Michigan.
  • April 6, 2026; the court blamed careless AI use by pro se filers.
Caught, not sanctioned Eve 2026-03-27
Ross LeBlanc filed briefs citing a real decision but quoting passages that did not exist, and the mistake was flagged with sanctions being sought.
Ross LeBlanc · Ross LeBlanc · 19th Judicial District Court in Baton Rouge · LA
businessinsider.com ↗
The file →
  • Ross LeBlanc, a Dudley DeBosier partner, was linked to the filings.
  • He filed briefs with quotes that did not exist in a real court decision.
  • The court had not yet imposed sanctions; opposing counsel sought them.
  • 19th Judicial District Court in Baton Rouge, Louisiana.
  • March 27, 2026 letter; LeBlanc said he started using Eve to draft pleadings.
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