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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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853
Incidents tracked
265
Incidents in 2026
$2,387,608
In fines, where reported
211 of 853 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 450 of 853 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 147 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 ClearBrief 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 248 Caught, not sanctioned 198 Warned 124 Referred to the bar 101 Reprimanded 86 Outcome unclear 56 Filing dismissed 37 Suspension 2 Upcoming sanction 1
Caught, not sanctioned ChatGPT
Farah Chalisa said she used ChatGPT for stylistic and grammatical review, and the court discussed the resulting AI-related citation problem.
Salah v. Walmart Inc. · Farah Chalisa · U.S. Court of Appeals for the Seventh Circuit
media.ca7.uscourts.gov ↗
The file →
  • Salah v. Walmart Inc.; Farah Chalisa
  • Chalisa said she used ChatGPT for stylistic and grammatical review
  • The page does not state any sanction or amount for this order
  • U.S. Court of Appeals for the Seventh Circuit
  • The page names ChatGPT and says Chalisa did not enter an appearance
Fined
A self-represented party relied on cases that did not exist or could not be found, and the Authority awarded increased costs.
O’Driscoll v Rehab Co Mobile Limited · Employment Relations Authority
minterellison.co.nz ↗
The file →
  • O’Driscoll v Rehab Co Mobile Limited involved a self-represented party.
  • The party cited cases that did not exist or could not be found.
  • The Authority awarded increased costs.
  • Employment Relations Authority, New Zealand.
  • [2026] NZERA 106; it noted the GenAI Guidelines had already been drawn to the applicant's attention.
Caught, not sanctioned
A self-represented litigant filed submissions citing a decision the court could not locate, likely generated by AI, and the court warned AI outputs must be verified.
LMN v STC (No 2) [2025] NZEmpC 46 · New Zealand Employment Court
minterellison.co.nz ↗
The file →
  • LMN v STC (No 2) [2025] NZEmpC 46; a self-represented litigant was involved
  • Filed a citation to a decision the court could not locate, likely AI-created
  • The court warned that AI outputs must be verified before filing
  • New Zealand Employment Court
  • 16 October 2025; no AI tool was named
Fined
Two lawyers were disciplined for filing briefs with AI hallucinations and barred from appearing in the Northern District of Mississippi for two years.
Mississippi disciplinary matter · Northern District of Mississippi · MS
attorneyatlawmagazine.com ↗
The file →
  • Mississippi disciplinary matter; two lawyers were disciplined
  • They submitted briefs with AI hallucinations
  • They were barred from appearing for two years and fined
  • Northern District of Mississippi, Mississippi
  • The article says this happened just before publication and gives no tool name
Caught, not sanctioned
A self-represented appellant filed an appeal with AI-generated citations, and the court questioned him about the documents.
Helmold & Mariya (No 2) [2025] FedCFamC1A 163 · Federal Circuit and Family Court of Australia, appellate division
““carried with it risks as well as opportunities”.”
aitken.com.au ↗
The file →
  • Helmold & Mariya (No 2) [2025] FedCFamC1A 163 involved a self-represented appellant.
  • He filed a Notice of Appeal and Summary of Argument with AI-generated material.
  • The court questioned him about the documents after finding cited cases that could not be located or did not support the propositions.
  • No sanction is reported on the page; the outcome described is a court warning, not punishment.
  • The appellate division of the Federal Circuit and Family Court of Australia cited Dame Victoria Sharp’s AI caution and said unverified AI research can mislead the court.
Filing dismissed
The court found opposition papers cited nonexistent opinions and dismissed the pro se complaint with prejudice.
Meril and Keith Dillard v. CBS Studios, Inc. · Meril and Keith Dillard · Federal court
“Because pro se parties are also bound by the Rule 11 duty to confirm that cited authorities exist and support their propositions, the court dismissed with prejudice, finding amendment would yield “additional unsupported allegations” and more defective filings rather than curing the complaint’s deficiencies.”
completeaitraining.com ↗
The file →
  • Meril and Keith Dillard v. CBS Studios, Inc. was a copyright action.
  • The filings included mischaracterizations, apparently AI-generated images, and an opposition brief citing several nonexistent opinions.
  • The court dismissed with prejudice, treating amendment as futile.
  • Federal court; the page gives no specific judge name or state.
  • The page says pro se parties still must verify authorities under Rule 11.
Caught, not sanctioned
The court found three cited authorities did not appear to exist and ordered counsel to show cause why sanctions should not be imposed.
Hernandez v. Lopez · Federal court
“While the Court does not prohibit counsel from using generative AI tools, counsel must comply with Rule 11(b), including confirmation that cases cited within a brief exist.”
completeaitraining.com ↗
The file →
  • Hernandez v. Lopez was a trademark dispute.
  • The brief contained three cited authorities that did not appear to exist and were likely hallucinated.
  • The court issued an order to show cause why sanctions should not be imposed.
  • Federal court; jurisdiction and state were not identified on the page.
  • The page quotes the court on Rule 11 and verifying cited cases.
Reprimanded ChatGPT
Forrister submitted AI-fabricated citations in a filing and faced discipline from the Texas Supreme Court.
In re: The State Bar of Texas v. Christopher W. Forrister · Christopher W. Forrister · Supreme Court of Texas · TX
caseread.ai ↗
The file →
  • Christopher W. Forrister was disciplined for AI-fabricated citations.
  • He filed a document that included fake citations generated by AI.
  • The Texas Supreme Court issued a reprimand.
  • The court was the Supreme Court of Texas.
  • The page names ChatGPT as the AI tool but gives no order date.
Warned
Attorney Thomas Guyer filed a brief with AI-generated misquotes and incorrect citations, and Judge Thomas Cullen declined to sanction him and issued a warning instead.
Thomas Guyer · Thomas Guyer · U.S. District Court for the Eastern District of Kentucky · KY
“sufficient deterrent”
theintake0.substack.com ↗
The file →
  • Thomas Guyer was the attorney reviewed by the court
  • He filed a brief with AI-generated misquotes and incorrect citations
  • Judge Thomas Cullen declined sanctions and gave a warning
  • U.S. District Court for the Eastern District of Kentucky
  • The article says Guyer was remorseful and had no history of misconduct

Showing 311–320 of 853.

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