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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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251
Incidents tracked
81
Incidents in 2026
$1,813,310
In fines, where reported
186 of 251 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 139 of 251 incidents; the rest are undated or fall outside this window.

Blamed by name

Counts only incidents where the filing court or the reporting named the tool.

Showing 211–220 of 251 incidents. Clear filters

Fined $18K 2025-09-26
Counsel filed a factum with hallucinated case authorities, and the court later ordered costs paid personally by appellant's lead counsel.
Reddy v. Saroya · Christopher Souster of Nimmons Law Office · Court of Appeal of Alberta · AB
“When used without safeguards, large language models frequently introduce confusion and delay into proceedings, and worse, constitute an abuse of process that may potentially bring the administration of justice into disrepute.”
canadianlawyermag.com ↗
The file →
  • Reddy v Saroya involved the appellant's lead counsel.
  • The factum contained fabricated case authorities and seven cited cases could not be found.
  • The court later ordered $17,550 plus GST payable personally by counsel.
  • Court of Appeal of Alberta, Alberta.
  • The page links the issue to a large language model but does not name a specific tool.
Fined $2K ChatGPT 2025-09-23
Lawrence Chang filed a reconsideration motion with AI-generated bogus citations and the court struck the motion and sanctioned him.
Lawrence Chang · Lawrence Chang · 459th District Court in Travis County · TX
“The court finds “good cause supports the imposition of sanctions in order to deter such conduct in the future, which amounts to serious misconduct that threatens to impugn the integrity of the courts and the administration of justice,” Guerra Gamble said.”
news.bloomberglaw.com ↗
The file →
  • Lawrence Chang was sanctioned in a Texas state-court matter involving his motion for reconsideration.
  • He admitted using AI and not checking the accuracy of the citations it produced.
  • The court ordered him to pay $2,000 in attorneys’ fees and expenses and struck the reconsideration motion.
  • Judge Maya Guerra Gamble issued the order in Texas state court.
  • Chang said he pasted his draft into ChatGPT’s legal tool to improve his writing.
Fined $24K 2025-09-23
Two lawyers filed motions with at least 55 defective citations; the court trimmed fee sanctions and ordered them to pay opposing firms.
Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol · Ibrahim Reyes; Jose R. Olmo-Rodriguez · U.S. District Court for the District of Puerto Rico · PR
““but the sheer number of inaccurate or nonexistent citations suggests otherwise,””
abajournal.com ↗
The file →
  • Ibrahim Reyes and Jose R. Olmo-Rodriguez were sanctioned in Puerto Rico.
  • They filed motions with at least 55 defective citations that the court said suggested AI use.
  • The court ordered $24,492 in fees, not the nearly $88,000 sought.
  • U.S. District Court for the District of Puerto Rico.
  • Sept. 23 opinion by Chief U.S. District Judge Raúl Arias-Marxuach; the court said the citations were inaccurate or nonexistent.
Fined $1K 2025-09-22
The court sanctioned plaintiffs’ counsel after briefs in two related cases included AI-generated false citations with real case names but fake quotes and parentheticals.
Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC · William G. Tishkoff and Christopher M. Vukelich · U.S. District Court for the Eastern District of Michigan · MI
“At this point, it ‘is no secret that generative AI programs are known to ‘hallucinate’ nonexistent cases, and with the advent of AI, courts have seen a rash of cases in which both counsel and pro se litigants have cited such fake, hallucinated cases, in their briefs,’”
minnlawyer.com ↗
The file →
  • Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC; plaintiffs’ counsel William G. Tishkoff and Christopher M. Vukelich
  • Briefs in two related cases contained AI-generated false citations with real case names but fake quotes and parentheticals
  • Judge Behm imposed monetary sanctions and ordered plaintiffs’ counsel to pay defense costs
  • U.S. District Court for the Eastern District of Michigan, Detroit, Michigan
  • Order issued Sept. 22, 2025; court said the errors were not in bad faith but still warranted deterrence
Fined $600 2025-09-19
A pro se litigant filed papers with fabricated citations, false quotes, and misrepresented legal norms; the court imposed a $600 monetary sanction.
Ali v. IT People Corporation · E.D. Michigan · MI
damiencharlotin.com ↗
The file →
  • Ali v. IT People Corporation involved a pro se litigant.
  • The submission used fabricated citations, false quotes, and misrepresented legal norms.
  • The court imposed a $600 monetary sanction.
  • The case was in E.D. Michigan.
  • Date: 2025-09-19; the database labels the AI use as implied.
Fined 2025-09-15
Justice Mary V. Rosado sanctioned Tyrone Blackburn after his motion papers cited non-existent cases and contained incorrect and false citations.
Monique Facey v. Liane Fisher et al. · Tyrone Blackburn · NY Sup. Ct., NY Cty. · NY
posts.diddydocket.com ↗
The file →
  • Monique Facey v. Liane Fisher et al.; Tyrone Blackburn was sanctioned.
  • His motion papers were riddled with incorrect and false citations.
  • The court awarded sanctions and fees.
  • NY Sup. Ct., NY Cty., New York state court.
  • 2025-09-15; Justice Mary V. Rosado ordered him to explain whether he used AI chatbots.
Fined $10K ChatGPT 2025-09-12
Amir Mostafavi filed appellate briefs with fabricated AI-generated citations and quotations, and the California Court of Appeal sanctioned him $10,000 and referred him to the state bar.
Noland v. Land of the Free, L.P. · Amir Mostafavi · California Court of Appeal · CA
“Nearly all of the legal quotations in plaintiff’s opening brief, and many of the quotations in plaintiff’s reply brief, are fabricated,”

Cases that don't exist

  • Schimmel v. Levin (2011) 195 Cal.App.4th 81
llms-for-lawyers.com ↗
The file →
  • Noland v. Land of the Free involving an appellate attorney.
  • Brief contained 21 fabricated quotations out of 23 using ChatGPT, Claude, Gemini, and Grok.
  • Fined $10,000 and referred to the State Bar; winning opponents denied fees for failing to report fakes.
  • California Court of Appeal (2d Dist., 114 Cal. App. 5th 426).
  • Dated September 12, 2025; established obligation for opposing parties to notify court of fakes.
Fined $13K ChatGPT 2025-09-12
A federal judge sanctioned Hagens Berman Sobol Shapiro, Robert Carey, and Celeste Boyd after briefs in an OnlyFans case contained AI-generated hallucinated citations.
N.Z. v. Fenix International Ltd. · Hagens Berman Sobol Shapiro; Robert Carey; Celeste Boyd · U.S. District Court for the Central District of California · CA
“He wrote that allowing revisions would unfairly burden defendants who had already responded, noting that the proposed corrections still contained errors.”
complex.com ↗
The file →
  • OnlyFans users v. Fenix International Ltd. involved Hagens Berman Sobol Shapiro, Robert Carey, and Celeste Boyd.
  • Four briefs reportedly contained fabricated or hallucinated legal citations generated through AI tools.
  • Judge Fred Slaughter imposed $10,000 on the firm and Carey, plus $3,000 on Boyd.
  • U.S. District Court for the Central District of California; Seattle-based firm; California federal case.
  • The article says Boyd used ChatGPT to draft and edit sections and failed to independently verify the output.
Fined $2K 2025-09-12
The court ordered a $2,418 monetary sanction and bar notification after a lawyer submitted fabricated case citations and false quotes.
Yi-Sheng Fang v. Hechalou US LLC · C.D. California · CA
damiencharlotin.com ↗
The file →
  • Yi-Sheng Fang, et al. v. Hechalou US LLC, et al. involving an unnamed lawyer
  • Lawyer submitted two fabricated case citations and two false case quotes
  • Imposed a $2,418 monetary sanction, bar notification, and compliance declaration
  • U.S. District Court for the Central District of California (C.D. California)
  • Order issued on September 12, 2025; unidentified AI tool used
Fined $2K 2025-09-09
The court fined an attorney $1,500, ordered service of the order on her client, and referred the order to the State Bar of California after she denied using AI.
Teniah Tercero v. Sacramento Logistics, LLC · U.S. District Court for the Eastern District of California · CA
sternekessler.com ↗
The file →
  • Tercero v. Sacramento Logistics, LLC involved a female attorney who denied using AI.
  • Attorney submitted fabricated legal citations and falsely denied utilizing artificial intelligence.
  • Court imposed a $1,500 monetary fine, client notification, and clerk referral to the State Bar of California.
  • U.S. District Court for the Eastern District of California.
  • Sanctioned on 2025-09-09 highlighting penalties for concealing AI reliance.
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