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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 171–180 of 199 incidents. Clear filters

Caught, not sanctioned 2025-09-03
A court-appointed special master found Dr. Sawyer cited nonexistent sources from AI use and said the error might warrant costs and cross-examination but not exclusion.
In re: Valsartan Losartan, and Irbesartan Products Liability Litigation · Dr. Sawyer · U.S. District Court for the District of New Jersey · NJ
“Dr. Sawyer's citation to non-existent sources due to his use of an artificial intelligence tool without adequate verification of the sources generated by the artificial intelligence tool, while perhaps warranting an award of costs in favor the defense and permitting cross examination of Dr. Sawyer during the trial on his failure to verify the sources cited in his report, does not warrant exclusion of his opinions as they are otherwise the product of reliable scientific methodology and are supported by "good grounds," especially given "the liberal thrust of the Federal Rules of Evidence, the flexible nature of the Daubert inquiry, and the proper roles of the judge and jury in evaluating the ultimate credibility of an expert's opinion" ….”
reason.com ↗
The file →
  • In re: Valsartan Losartan, and Irbesartan Products Liability Litigation; Dr. Sawyer was challenged over fake citations in his expert report.
  • He used an artificial intelligence tool to help locate sources, and multiple cited sources were found to be nonexistent.
  • The court did not exclude his opinions, but said the problem could warrant costs and cross-examination.
  • U.S. District Court for the District of New Jersey; the article says the decision was handed down Sept. 3.
  • The page says Dr. Sawyer and counsel never identified the particular AI tool, and the judge cited the liberal thrust of the FRE and Daubert.
Caught, not sanctioned 2025-09-01
A Delhi High Court petition was withdrawn after opposing counsel exposed entirely fabricated citations and phantom paragraphs from a real judgment.
Delhi High Court September 2025 matter · Delhi High Court
medianama.com ↗
The file →
  • Delhi High Court petition
  • Opposing counsel exposed entirely fabricated citations, including phantom paragraphs
  • The petition was withdrawn; no sanction is stated
  • Delhi High Court
  • September 2025; the article says the real judgment had only 27 paragraphs
Caught, not sanctioned 2025-08-19
Wheatley J said AI-generated references were fabricated and misleading and adopted redaction of false case citations.
JML Rose Pty Ltd v Jorgensen · Federal Court of Australia
“There has been an approach, which I will adopt, of redacting false case citations so that such information is not further propagated by AI systems.”
eggernotes.com ↗
The file →
  • JML Rose Pty Ltd v Jorgensen (No 3) in the Federal Court of Australia
  • The court discussed erroneously generated references that were fabricated, fictional, false and fake
  • No sanction amount or sanction was reported on the page
  • Federal Court of Australia, Australia
  • 19 August 2025; Wheatley J said false case citations should be redacted
Caught, not sanctioned 2025-08-19
A trial court order cited four AI-generated non-existent cases, and the High Court refused to set it aside and dismissed the revision.
R.P.No.1658 of 2023 · Andhra Pradesh High Court
“The Court held that an order is not vitiated by the mere inclusion of non-existent AI-generated citations if the legal principles applied to the facts are correct under the law of the land.”

Cases that don't exist

  • Subramani v. M.Natarajan((2013) 14 SCC 95
  • Chidambaram PIllai v. SAL Ramasamy(1071 (2) SCC 68
  • Lakshmi Devi v. K.Prabha((2006) 5 SCC 551

+1 more

lekhanews.in ↗
The file →
  • R.P.No.1658 of 2023 in the Andhra Pradesh High Court
  • Trial court order relied on four AI-generated non-existent citations
  • High Court dismissed the revision; no sanction was imposed
  • Andhra Pradesh High Court, Vijayawada, Andhra Pradesh
  • Decided 2025-08-19; judge accepted the trial judge's explanation and warned to verify sources
Caught, not sanctioned ChatGPT 2025-08-08
Former Maine lawyer Seth Carey was denied law license reinstatement after submitting a motion drafted with ChatGPT containing unchecked, erroneous case citations.
Seth Carey · Seth Carey · Penobscot County Superior Court · ME
“This conduct is incredibly striking and negatively reflects on multiple criteria for reinstatement.”
bangordailynews.com ↗
The file →
  • Seth Carey sought reinstatement of his suspended Maine law license.
  • Carey used ChatGPT to write a motion and failed to verify the AI-generated citations.
  • Judge Ann Murray denied his reinstatement request without imposing monetary sanctions.
  • The decision was issued in Penobscot County Superior Court, Maine.
  • The court ruled on August 8 after finding Carey failed to show progress or competence.
Caught, not sanctioned 2025-08-01
A Victorian solicitor filed AI-generated content with inaccurate citations and was later disciplined by the Victorian Legal Services Board.
Dayal [2024] FedCFamC2F 1166 · Federal Circuit and Family Court of Australia
lst.org.au ↗
The file →
  • Dayal [2024] FedCFamC2F 1166 involved a Victorian solicitor
  • The solicitor filed AI-generated content containing inaccurate citations
  • The Victorian Legal Services Board imposed discipline including loss of principal rights and trust-money authority
  • The underlying matter was in the Federal Circuit and Family Court of Australia
  • In August 2025, the sanction included two years of supervised practice with quarterly reporting
Caught, not sanctioned 2025-08-01
A Victorian solicitor filed fictional AI-generated cases in the Federal Circuit and Family Court of Australia and lost his ability to practise as a principal lawyer, handle trust money and operate his own practice.
Victorian solicitor matter · Federal Circuit and Family Court of Australia
mccullough.com.au ↗
The file →
  • A Victorian solicitor was sanctioned in the Federal Circuit and Family Court of Australia.
  • He submitted fictional AI-generated cases to the court.
  • He lost his ability to practise as a principal lawyer, handle trust money and operate his own practice.
  • Federal Circuit and Family Court of Australia; Australia.
  • August 2025; the page says this was the first Australian lawyer sanctioned for misusing AI in court.
Caught, not sanctioned Perplexity AI 2025-07-23
A clerk used Perplexity AI and produced fabricated party names, invented precedents, and wrong statements of state law, leading Judge Henry T. Wingate to vacate the order.
Jackson Fed’n of Teachers v. State · Southern District of Mississippi · MS
“technical mistake”
wabarnews.org ↗
The file →
  • Jackson Fed’n of Teachers v. State; a clerk
  • Used Perplexity AI and generated fabricated party names and invented precedents
  • Order was vacated; no sanction amount stated
  • U.S. District Court for the Southern District of Mississippi
  • July 23, 2025; Judge Henry T. Wingate tried to remove the original from the public docket
Caught, not sanctioned 2025-07-23
An LIP filed fabricated tax cases generated by AI, and the Upper Tribunal declined sanctions while noting systemic risks.
HMRC v Gunnarsson · Upper Tribunal
thebarristergroup.co.uk ↗
The file →
  • HMRC v Gunnarsson involved an LIP and fabricated tax cases.
  • The LIP relied on hallucinated authorities generated by AI.
  • The Upper Tribunal declined sanctions and expressed sympathy.
  • The court was the Upper Tribunal in the UK.
  • The page says the ruling warned that repeated hallucinations could force courts to verify every citation.
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