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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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851
Incidents tracked
262
Incidents in 2026
$2,417,608
In fines, where reported
214 of 851 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 446 of 851 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 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 251 Caught, not sanctioned 199 Warned 126 Referred to the bar 98 Reprimanded 85 Outcome unclear 53 Filing dismissed 36 Suspension 2 Upcoming sanction 1
Fined $2K Lexis+ AI
Lindsay filed memoranda of law with fabricated citations and was sanctioned $2,500 after the court found she used AI-generated hallucinations.
Jimenez-Fogarty v. Fogarty · Tricia S. Lindsay · U.S. District Court for the Southern District of New York, Magistrate Judge Gabriel W. Gorenstein · NY
“"[C]ourts in this [C]ircuit have repeatedly found that presenting AI-generated hallucinations as valid caselaw constitutes subjective bad faith."”
holonlaw.com ↗
The file →
  • Jimenez-Fogarty v. Fogarty; Tricia S. Lindsay was sanctioned.
  • She filed two memoranda of law citing numerous nonexistent cases.
  • The court imposed a $2,500 fine and required notice to her client and other judges.
  • U.S. District Court for the Southern District of New York; Magistrate Judge Gabriel W. Gorenstein.
  • The opinion said Lindsay used an AI program and referenced Lexis Nexis AI-driven features.
Fined $1K ChatOn
The plaintiff’s reply brief used ChatOn to create false case citations, and the court ordered the attorney to pay a $1,000 penalty.
Benjamin v. Costco Wholesale Corp. · U.S. District Court for the Eastern District of New York · NY
holonlaw.com ↗
The file →
  • Benjamin v. Costco Wholesale Corp.; the plaintiff’s attorney was penalized
  • The reply brief included numerous case citations created by ChatOn that were false
  • The court ordered a $1,000 penalty
  • U.S. District Court for the Eastern District of New York
  • Magistrate Judge Lee G. Dunst found mitigating factors, including remorse and voluntary CLE participation
Caught, not sanctioned
Counsel cited a nonexistent authority in an opening brief and delayed correcting it, but the court declined to impose sanctions.
Lichfield v. Kubler · U.S. Court of Appeals for the Tenth Circuit
holonlaw.com ↗
The file →
  • Lichfield v. Kubler involved an opening brief citing a fake authority.
  • Counsel cited one nonexistent case and misrepresented two real cases, correcting them late.
  • The court declined to impose sanctions, issuing a warning instead.
  • Decided by the Tenth Circuit (183 F.4th 1248).
  • The court held hallucinated citations must be corrected explicitly and without prompting.
Reprimanded
A lawyer filed an appellate brief with eight DEA adjudications, seven misrepresented and one nonexistent, and the Third Circuit reprimanded him.
McCarthy v. United States Drug Enforcement Administration · U.S. Court of Appeals for the Third Circuit
“Attorney has harmed his credibility with this Court.”
holonlaw.com ↗
The file →
  • McCarthy v. United States Drug Enforcement Administration; the physician assistant’s lawyer was sanctioned.
  • He filed an opening brief using eight DEA adjudications from his client, but seven were misrepresented and one did not exist.
  • The Third Circuit reprimanded him in a precedential decision, with no monetary penalty imposed.
  • U.S. Court of Appeals for the Third Circuit; Judge Cindy Chung authored the decision.
  • The court said it would have imposed a monetary penalty absent the lack of prior Third Circuit guidance.
Fined $3K ChatGPT
Walters filed papers with hallucinated citations; the court sanctioned him for the fake authorities.
Park v. Kim · Mark Walters · U.S. District Court, Southern District of New York · NY
“The opinion is short and direct.”

Cases that don't exist

  • Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014)
holonlaw.com ↗
The file →
  • Park v. Kim; Mark Walters was sanctioned
  • He filed briefs containing hallucinated legal citations
  • $3,000 monetary fine
  • U.S. District Court, Southern District of New York, New York
  • The page links the misconduct to ChatGPT-generated fake citations
Fined $60K
A law firm partner and the firm were sanctioned $59,500 combined after submitting roughly 14 fabricated or misrepresented citations in a lawsuit.
Mack v. Anderson · Goldberg Segalla · Cook County Circuit Court · IL

Cases that don't exist

  • Mack v. Anderson
yesh.world ↗
The file →
  • Lead-paint poisoning suit involving a Goldberg Segalla partner and the law firm
  • Submitted roughly 14 fabricated or misrepresented citations in court filings, including Mack v. Anderson
  • Monetary fine of $10,000 for the partner and $49,500 for the firm, totaling $59,500
  • Cook County court in Chicago, Illinois
  • Reported in December 2025 regarding fabricated legal citations submitted to the court
Reprimanded ChatGPT
An Oklahoma Supreme Court reprimanded an attorney for submitting legal motions containing AI-generated fake case citations.
Lawrence Wheeler · Lawrence Wheeler · Oklahoma Supreme Court · OK
“the careless use of generative artificial intelligence … damages the integrity and credibility of the legal system.”

Cases that don't exist

  • Cummings v. Cimarron Elevator Co.
  • Hawkins v. Linhart
oklahoman.com ↗
The file →
  • An unnamed attorney was reprimanded by the Oklahoma Supreme Court.
  • The attorney submitted legal motions containing AI-generated fabrications.
  • The sanction imposed was a formal public reprimand.
  • The matter was handled by the Oklahoma Supreme Court.
  • The reprimand occurred in May (year not specified); the court warned AI misuse damages legal integrity.
Warned
A taxpayer's attorney cited three fictitious AI-generated cases in a brief and failed to correct them, prompting a sanctions warning from the Tax Court.
Clinco · United States Tax Court
“submitting a brief with fictitious caselaw is a recipe for sanctions”

Cases that don't exist

  • Cacchillo, 130 T.C. 132 (2008)
  • Miller, 57 T.C. 440 (1971)
  • Tefel, 118 T.C. 324 (2002)
omegatechnologysolutionsgroupinc.com ↗
The file →
  • Clinco (T.C. Memo. 2026-16) involving an unnamed taxpayer's attorney
  • Attorney cited three fake AI-hallucinated cases regarding deficiency notices
  • Court issued a stark warning that filing fictitious caselaw is a recipe for sanctions
  • U.S. Tax Court before Judge Mark V. Holmes
  • No specific incident date or AI tool name provided in the text
Warned
An appellate court ordered an attorney to show cause why she should not be sanctioned for submitting unfocused filings containing 'AI slop' and gibberish.
Jaclyn Soroka · Jaclyn Soroka · Florida 4th District Court of Appeal · FL
“an AI supercomputer would struggle to find meaning in some of the prose used in this case”
theoutpost.ai ↗
The file →
  • Jaclyn Soroka was warned and ordered to show cause by a Florida appellate panel.
  • She submitted lengthy, unfocused filings filled with 'AI slop' and frivolous arguments.
  • The court warned of potential sanctions and issued an order to show cause.
  • The ruling came from the Florida 4th District Court of Appeal.
  • Judge Robert Gross noted an AI supercomputer would struggle to find meaning in the prose.
Reprimanded ChatGPT
The court reprimanded an attorney for filing a murder appeal brief containing hallucinated police testimony generated by ChatGPT.
State of New Mexico v. Manuel Sifuentes · L. Helen Bennett · New Mexico Supreme Court · NM
threads.com ↗
The file →
  • State v. Sifuentes involved defense attorney L. Helen Bennett.
  • Bennett used ChatGPT to draft a brief containing fabricated police testimony.
  • The New Mexico Supreme Court issued a formal public reprimand.
  • The ruling was handed down by the New Mexico Supreme Court.
  • The court noted ChatGPT invented testimony not in the actual trial record.

Showing 11–20 of 851.

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