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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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19
Incidents tracked
5
Incidents in 2026
$0
In fines, where reported
0 of 19 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 5 of 19 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 19 Copilot 5 AI-assisted legal software 2 ChatGPT-4o 1 Claude 1 CoCounsel 1 Lexis+ AI 1 Strongsuit 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 11–19 of 19 incidents involving ChatGPT. Clear filters

Warned ChatGPT 2026-05-05
Kelly Guagenty filed a brief with AI-caused citation errors, mischaracterizations and an improper quotation; Judge Stacey D. Neumann ordered AI training and new safeguards but no fine.
Jessica Fuller v Hyde School · Karen Guagenty · U.S. District Court for the District of Maine · ME
“Although AI can be a useful aid in research and drafting, its use does not diminish an attorney's nondelegable duties of diligence, candor, and reasonable inquiry.”
habeas.ai ↗
The file →
  • FULLER v. HYDE SCHOOL involved Attorney Kelly Guagenty.
  • She submitted two filings with AI-generated erroneous legal citations.
  • The court imposed non-monetary sanctions.
  • United States District Court for the District of Maine, Maine.
  • May 5, 2026; counsel said the AI used was either Claude or ChatGPT.
Warned ChatGPT 2026-03-01
Several authorities and citations in judicial review grounds could not be located; the Tribunal found the errors consistent with AI-hallucination risk and accepted a supervising solicitor's explanation.
R(Munir) and SOSHD · Upper Tribunal Immigration and Asylum Chamber
““Freely available generative artificial intelligence tools, trained on a large language model such as ChatGPT are not capable of conducting reliable legal research.”
naturalandartificiallaw.com ↗
The file →
  • R(Munir) and SOSHD concerned false authorities and citations in judicial review grounds.
  • The Tribunal found the pattern of errors consistent with AI-hallucination risk.
  • The supervising solicitor accepted that false citations generated by AI may have been used.
  • Upper Tribunal Immigration and Asylum Chamber, UK.
  • 2026-03-01; the Tribunal stressed supervision and accurate checking of documents.
Warned ChatGPT 2026-02-22
Three lawyers received a warning and two had to take a mandatory course after citing non-existent judgments generated by ChatGPT in court filings.
First disciplinary measures for lawyers · Judges in Arnhem, Rotterdam, and Groningen
verileges.nl ↗
The file →
  • Three lawyers were disciplined.
  • They cited non-existent judgments generated by ChatGPT.
  • The sanctions were a warning and mandatory course, with no amount stated.
  • Judges in Arnhem, Rotterdam, and Groningen.
  • 22 February 2026; the page says this was the first disciplinary measure.
Warned ChatGPT 2026-01-29
The appellant used ChatGPT to draft legal submissions and cited cases the tribunal could not locate; the tribunal refused his application and noted possible referral if he were registered.
Folarin v The Immigration Services Commissioner [2026] UKFTT 135 · UK First-tier Tribunal
““This would have had the effect of misleading the Tribunal had the Tribunal not challenged the point.””
naturalandartificiallaw.com ↗
The file →
  • Folarin v The Immigration Services Commissioner; the appellant's submissions
  • He used ChatGPT and other AI tools to find and summarize cases, some of which could not be located
  • No formal sanction, but the tribunal found he was not fit to provide immigration advice
  • UK First-tier Tribunal
  • 2026; tribunal stressed that false citations could mislead and that a future regulator referral was possible
Warned ChatGPT 2026-01-22
A lawyer used ChatGPT to generate fabricated case citations and was ordered by the court to inform their client and staff of the errors.
That Xiong v. Minga Wofford (1) · E.D. California · CA
damiencharlotin.com ↗
The file →
  • That Xiong v. Minga Wofford (1)
  • Lawyer used ChatGPT to generate fabricated case law citations.
  • Ordered to inform client and staff of errors.
  • U.S. District Court for the Eastern District of California
  • Decided January 22, 2026; ChatGPT explicitly cited as the tool used.
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
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
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.
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