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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 151–160 of 199 incidents. Clear filters

Caught, not sanctioned 2026-01-16
Mingione filed two motions to strike that allegedly contained AI-hallucinated quotes and nonexistent cases; sanctions were sought against him and his client.
J. Salvatore & Sons Inc. v. Gencor Contracting Corp. · Nicholas Mingione · Connecticut Superior Court in Danbury · CT
“"a lawyer shall not knowingly make a false statement of material fact or law to a tribunal."”
ctinsider.com ↗
The file →
  • J. Salvatore & Sons Inc. v. Gencor Contracting Corp.; Nicholas Mingione was accused
  • He filed two motions to strike with bogus and hallucinated case law, including citations that did not exist
  • Philip Russell sought sanctions, but the article reports only a request, not an imposed sanction
  • State Superior Court in Danbury, Connecticut
  • Jan. 16, 2026; Mingione said his legal research software had an AI component
Caught, not sanctioned 2026-01-07
The court issued an order in a pro se case addressing AI use and requiring citation verification.
Hollinger v. Enlisted Ass’n of the Nat’l Guard of the United States · U.S. District Court for the Eastern District of Virginia · VA
bakerbotts.com ↗
The file →
  • Hollinger v. Enlisted Ass’n of the Nat’l Guard of the United States
  • A pro se matter triggered an EDVA AI-related case-specific order
  • No sanction or amount is stated on the page
  • U.S. District Court for the Eastern District of Virginia
  • Jan. 7, 2026; cited as one of two recent EDVA examples
Caught, not sanctioned 2026-01-01
Plaintiff’s counsel admitted using AI to prepare a factum that included a nonexistent quote and mismatched principles; the court said AI misuse would affect costs.
RSR Road Surface Recycling v. Bonnechere Excavating et al. · Ontario Superior Court of Justice
lawtimesnews.com ↗
The file →
  • RSR Road Surface Recycling v. Bonnechere Excavating et al.; counsel for plaintiff
  • AI was used to prepare the factum and produced hallucinated material
  • The court said AI misuse would be factored into costs
  • Ontario Superior Court of Justice
  • 2026; counsel admitted using AI software
Caught, not sanctioned 2025-12-18
The court voided the control procedure and canceled a repayment claim after finding the plaintiff's cited case law did not match published decisions.
Tribunal judiciaire de Périgueux, n° 23/00452 · Tribunal judiciaire de Périgueux (Pôle social)
“requested the plaintiff and his lawyer to check in future that references found via search engines or generative AI are not hallucinations.”
konbriefing.com ↗
The file →
  • Tribunal judiciaire de Périgueux, n° 23/00452; the plaintiff and his lawyer
  • Plaintiff cited case-law references that did not correspond to published decisions
  • No sanction was imposed; the court instead canceled the repayment claim
  • Tribunal judiciaire de Périgueux (Pôle social), Périgueux, France
  • 2025-12-18; court warned to verify references from search engines or generative AI
Caught, not sanctioned 2025-12-17
A brief cited fake cases, and Judge Johnston did not impose sanctions, likely because the litigant was pro se.
In Halpern v. FRB of N.Y. · Northern District of Illinois · IL
tresslerllp.com ↗
The file →
  • In Halpern v. FRB of N.Y. involved fake-case citations.
  • The court received a brief citing fake cases but imposed no sanctions.
  • The article says leniency was likely due to the pro se litigant.
  • Northern District of Illinois, federal court in Illinois.
  • Dec. 17, 2025; Judge Johnston was one of the judges mentioned.
Caught, not sanctioned 2025-12-15
The court found the reopening request relied on non-existent case law, likely from uncontrolled AI use, and treated the conduct as bad faith and disruptive.
Ondernemingsrechtbank Gent, ECLI:BE:ORGNT:2025:JUG.20251215.1 · Ondernemingsrechtbank Gent
konbriefing.com ↗
The file →
  • Ondernemingsrechtbank Gent; the company
  • The reopening request cited non-existent case law likely produced by uncontrolled AI
  • The court found bad faith and disruption but imposed no stated sanction
  • Ghent, Belgium
  • 2025-12-15; insolvency proceedings before the commercial court
Caught, not sanctioned ChatGPT 2025-12-10
A pro se claimant used ChatGPT to generate fabricated case law, and the tribunal awarded a preparation time order of £2,178 stayed pending appeal.
Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy · Employment Tribunals (Leeds)
damiencharlotin.com ↗
The file →
  • Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy involved AI-generated citations.
  • ChatGPT generated fabricated case law in the pleadings.
  • The tribunal awarded a preparation time order of £2,178, stayed pending EAT appeal.
  • Employment Tribunals (Leeds), UK.
  • 10 December 2025; the page says the payment was stayed pending appeal.
Caught, not sanctioned 2025-12-09
The court found the plaintiff had cited case-law references that could not be located, indicating hallucinated AI-generated references, but imposed no sanctions.
Tribunal argentino apercibe a abogado que utilizó inteligencia artificial para redactar escrito con jurisprudencia inexistente · Cámara del Trabajo - 1ra Circ. - Viedma
“However, the court did not impose any sanctions, as the incident occurred before a relevant regulation came into force.”
konbriefing.com ↗
The file →
  • Tribunal argentino apercibe a abogado que utilizó inteligencia artificial para redactar escrito con jurisprudencia inexistente; the plaintiff's lawyer
  • The plaintiff filed a brief with uncitable case-law references likely generated by AI
  • No sanctions were imposed because a relevant regulation was not yet in force
  • Cámara del Trabajo - 1ra Circ. - Viedma, Argentina
  • 2025-12-09; the court warned against AI hallucinations
Caught, not sanctioned 2025-12-04
A brief cited fake cases, and Judge Pallmeyer did not impose sanctions, likely because the litigant was pro se.
Dorsey v. Ponce et al · Northern District of Illinois · IL
tresslerllp.com ↗
The file →
  • Dorsey v. Ponce et al involved fake-case citations.
  • The court received a brief citing fake cases but imposed no sanctions.
  • The article says leniency was likely due to the pro se litigant.
  • Northern District of Illinois, federal court in Illinois.
  • Dec. 4, 2025; Judge Pallmeyer was one of the judges mentioned.
Caught, not sanctioned ChatGPT 2025-12-04
McGuire Woods filed a brief with fake citations, and the court sanctioned the lawyer and ordered the firm to explain itself.
Ringer v. Bank of America, N.A. · McGuire Woods LLP · U.S. District Court for the Northern District of Georgia · GA
“In other words, the Court must be concerned with the message sent to other lawyers, firms and non represented parties as to the consequences of cutting corners, by using tools such as ChatGPT or even AI modules offered by reputable legal research databases without adequate care, or otherwise failing to verify the accuracy of citations and assertions in legal filings.”
tcpaworld.com ↗
The file →
  • Ringer v. Bank of America; McGuire Woods LLP was involved.
  • A lawyer filed a brief containing a ton of fake cites.
  • The court sanctioned the lawyer and required the firm to explain itself.
  • U.S. District Court for the Northern District of Georgia.
  • Dec. 4, 2025; the court said careless citation errors must not be tolerated.
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