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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 141–150 of 151 incidents involving ChatGPT. Clear filters

Filing dismissed $10K ChatGPT 2024-01-01
A litigant submitted an appellate brief with fictitious AI-generated case citations, and the Missouri Court of Appeals dismissed the appeal and imposed damages.
Kruse v. Karlen · Jonathan Karlen · Missouri Court of Appeals · MO
“The Court of Appeals noted that the “bogus citations” could not, “for any reason….be countenanced and represent a flagrant violation of the duty of candor” owed to the court.”
nysba.org ↗
The file →
  • Kruse v. Karlen involved a self-represented appellant.
  • Her AI program cited 24 cases, but only two were real and both were misunderstood.
  • The court dismissed the appeal and ordered $10,000 in attorney’s fees.
  • Missouri Court of Appeals, Missouri.
  • The article says the AI made up case names and citations that appeared genuine.
Reprimanded ChatGPT 2023-11-22
Attorney Zachariah Crabill received a 90-day suspension after filing fabricated ChatGPT citations in a custody case and lying to the judge about their origin.
People v. Crabill · Zachariah C. Crabill · Office of the Presiding Disciplinary Judge of the Supreme Court of Colorado · CO
“In November 2023, a Colorado disciplinary judge approved a suspension of one year and one day, with 90 days to serve, for violations including competence, diligence, and candor to the tribunal.”
llms-for-lawyers.com ↗
The file →
  • Attorney Zachariah Crabill filed court documents containing fake legal citations.
  • The fake citations were generated using ChatGPT, and Crabill initially blamed an intern.
  • Crabill was suspended for a year and a day, with 90 days served and the rest stayed on probation.
  • Adjudicated by Colorado's presiding disciplinary judge.
  • The disciplinary sanction was handed down in November 2023.
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
Fined $10K ChatGPT 2023-06-30
Morris, Nichols, Arsht & Tunnell LLP submitted a brief with hallucinated citations, and the court sanctioned the firm and counsel.
In re: CFI Delegated Shareholder Litigation · Morris, Nichols, Arsht & Tunnell LLP · Court of Chancery of the State of Delaware · DE
““The use of ChatGPT was not disclosed to the Court.””

Cases that don't exist

  • Hsu v. Teco Energy, Inc., 2018 WL 5115675
  • Morris v. 7-Eleven, Inc., 2015 WL 7293045
podcasts.apple.com ↗
The file →
  • In re: CFI Delegated Shareholder Litigation against Morris, Nichols, Arsht & Tunnell LLP
  • A filing included hallucinated citations generated with ChatGPT
  • The court imposed a $10,000 monetary sanction
  • Court of Chancery of the State of Delaware, Delaware
  • The order noted the use of ChatGPT was not disclosed to the court
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
Fined $5K ChatGPT 2023-06-22
Counsel cited six nonexistent, ChatGPT-generated cases in an opposition brief and then filed fabricated copies of the opinions when challenged.
Mata v. Avianca · Steven Schwartz, Peter LoDuca, and their firm · U.S. District Court for the Southern District of New York · NY
“Judge P. Kevin Castel sanctioned Schwartz, co-counsel Peter LoDuca, and their firm $5,000.”

Cases that don't exist

  • Miller v. DLA Piper LLP (US), 923 F.3d 1297
  • Zicherman v. Korean Air Lines Co., 516 U.S. 217
  • Varghese v. China Southern Airlines Co. Ltd., 925 F.3d 1339

+3 more

note.com ↗
The file →
  • In Mata v. Avianca, Inc., two attorneys and their firm were sanctioned.
  • They cited six nonexistent, ChatGPT-generated cases and filed fabricated opinions.
  • The sanction was a $5,000 penalty, jointly and severally.
  • The incident occurred in the S.D.N.Y. federal court.
  • On 2023-06-22, ChatGPT was identified as the AI tool used, leading to letters to the client and falsely named judges.
Fined ChatGPT 2023-06-22
A New York lawyer was sanctioned after filing briefs with fake court cases generated by ChatGPT.
In re Cathleen Siebrecht · Cathleen Siebrecht · U.S. District Court for the Southern District of New York · NY
smallwarsjournal.com ↗
The file →
  • In re Cathleen Siebrecht involved Cathleen Siebrecht, a New York lawyer.
  • She filed briefs citing fake court cases produced by ChatGPT.
  • The court sanctioned her, but the article gives no amount.
  • U.S. District Court for the Southern District of New York.
  • The page says this happened in 2023 and ties the citations to a ChatGPT hallucination.
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.
Caught, not sanctioned ChatGPT 2023-01-01
Mrs Harber cited nine FTT decisions in her appeal to the First-Tier Tax Tribunal, but the tribunal and HMRC found that these cases did not exist and were generated by an AI system.
Harber v Commissioners for His Majesty’s Revenue and Customs [2023] UKFTT 1007 (TC) · Mrs Harber · First-tier Tribunal (Tax Chamber)
burges-salmon.com ↗
The file →
  • Harber v Commissioners for HMRC involved a self-represented appellant
  • Appellant submitted fictitious cases generated using ChatGPT to support a tax penalty appeal
  • The tribunal rejected the fake authorities and imposed no formal sanction due to her unrepresented status
  • Decided by the First-tier Tribunal (Tax Chamber) in the UK
  • Established early precedent that AI-generated fake cases carry no judicial weight
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