legaltech.fyi Beta

Tracker

Sanctions watch

Every incident where a lawyer got caught filing AI-fabricated citations. The Hall of Shame.

Embed this
53
Incidents tracked
12
Incidents in 2026
$280,119
In fines, where reported
44 of 53 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 23 of 53 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 53 Claude 4 Lexis+ AI 4 Westlaw Precision 4 CoCounsel 3 Copilot 2 AI-assisted legal software 1 Archie 1 ChatOn 1 ClearBrief 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 Gemini 1 Ghostwriter Legal 1 Google AI 1 Google Scholar 1 Grok 1 Irys 1 vLex Fastcase 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 41–50 of 53 incidents involving ChatGPT. Clear filters

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 $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 ChatGPT 2025-08-28
A pro se plaintiff filed a brief citing a non-existent Third Circuit case generated by AI, and Judge Karoline Mehalchick sanctioned him.
Allbaugh v. Univ. of Scranton · U.S. District Court for the Middle District of Pennsylvania · PA
“Rule 11 does not prohibit the use of generative AI, however, it does require parties to verify that they are not submitting briefs to the Court which rely on fictitious cases.”

Cases that don't exist

  • Allbaugh v. Univ. of Scranton, 2025 WL 2484188
cgalaw.com ↗
The file →
  • Allbaugh v. Univ. of Scranton involved a pro se plaintiff sanctioned for an AI-generated fake citation.
  • The plaintiff cited a non-existent Third Circuit opinion in a brief.
  • Judge Karoline Mehalchick imposed sanctions for the misuse of AI and the false citation.
  • The case was in the U.S. District Court for the Middle District of Pennsylvania.
  • On 2025-08-28, the court said parties must verify briefs do not rely on fictitious cases.
Fined $6K ChatGPT 2025-07-18
Thomas Nield used ChatGPT to research a Chapter 13 issue and filed briefs with nonexistent cases and quotes; Judge Michael Slade fined him $5,500.
In re Marla C. Martin · Thomas Nield · U.S. Bankruptcy Court for the Northern District of Illinois · IL
“The next lawyer who does the same thing is warned that he or she will likely see a more significant penalty.”
news.bloomberglaw.com ↗
The file →
  • Thomas Nield, a former Semrad Law Firm bankruptcy attorney, was sanctioned in Illinois.
  • He used ChatGPT and filed documents with hallucinated cases and quotes.
  • Judge Michael Slade imposed a $5,500 fine.
  • The sanction came from the Illinois bankruptcy court.
  • The article says he used ChatGPT for an ancillary issue in a Chapter 13 case and was terminated in September.
Fined $6K ChatGPT 2025-05-28
Attorney Rafael Ramirez was sanctioned $6,000 and subsequently resigned after submitting briefs containing fake AI-generated citations on three occasions.
Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC · Rafael Ramirez · U.S. Magistrate Judge Mark Dinsmore · IN
inkfreenews.com ↗
The file →
  • Mid Central Operating Engineers v. HoosierVac involving an attorney.
  • Submitted three court briefs relying on non-existent citations from generative AI.
  • Fined $6,000 (reduced from a recommended $15,000).
  • U.S. District Court for the Southern District of Indiana.
  • Dated May 28, 2025; involved repeated filing of fake authority across multiple submissions.
Fined $2K ChatGPT 2024-11-04
Judge Fred W. Slaughter imposed $2,000 in sanctions on William Becker Jr. for filing a motion with alleged non-existent case citations and misrepresentations of existing law.
William Becker Jr. · William Becker Jr · US District Court for the Central District of California · CA
“Sanctions were warranted against Becker for “his failure to verify the validity of the AI-generated material, and submitting the AI-tainted Motion to the court,” the judge said.”
news.bloomberglaw.com ↗
The file →
  • William Becker Jr. was sanctioned in the Chris Kluwe-related case.
  • He filed a motion with AI-hallucinated/non-existent citations and misrepresented existing case law.
  • The court imposed $2,000 in sanctions.
  • US District Court for the Central District of California; Judge Fred W. Slaughter.
  • Nov. 4 order; the page says the motion was AI-tainted and Becker was told to show cause.
Fined ChatGPT 2024-02-20
A lawyer submitted filings with AI-generated case citations; the BC Supreme Court declined special costs but held her personally liable for other costs.
Zhang v. Chen · counsel in Zhang v. Chen · Supreme Court of British Columbia, Canada · BC
“Citing fake cases in court filings and other materials handed up to the court is an abuse of process and is tantamount to making a false statement … Unchecked, it can lead to a miscarriage of justice.”
corp-intl.com ↗
The file →
  • In Zhang v. Chen, counsel faced sanctions.
  • Two fabricated cases were cited in a parenting time application, with delayed disclosure.
  • Special costs were refused, but costs were ordered personally against counsel.
  • The incident occurred in the Supreme Court of British Columbia, Canada, with Justice Masuhara.
  • On 2024-02-20, ChatGPT was admitted as the source, and counsel was ordered to review other files.
Fined $2K ChatGPT 2024-02-12
Plaintiff's counsel filed opposition memoranda containing four fictitious AI-generated citations and was fined $2,000 under Rule 11.
Smith v. Farwell · Suffolk Superior Court · MA
“two disturbing developments that are adversely affecting the practice of law”
klemchuk.com ↗
The file →
  • Smith v. Farwell involved plaintiff's counsel filing fictitious citations.
  • Counsel filed four memoranda with three containing four fake cases from an AI tool.
  • Court fined counsel $2,000 for Rule 11 violations.
  • Norfolk Superior Court, Massachusetts, presided over by Judge Brian A. Davis.
  • Date: February 2024; judge noted a defense based on ignorance will be less credible.
Fined $10K ChatGPT 2023-06-30
Morris, Nichols, Arsht & Tunnell LLP submitted a brief with hallucinated citations, and the court sanctioned the firm and counsel.
In re: CFI Delegated Shareholder Litigation · Morris, Nichols, Arsht & Tunnell LLP · Court of Chancery of the State of Delaware · DE
““The use of ChatGPT was not disclosed to the Court.””

Cases that don't exist

  • Hsu v. Teco Energy, Inc., 2018 WL 5115675
  • Morris v. 7-Eleven, Inc., 2015 WL 7293045
podcasts.apple.com ↗
The file →
  • In re: CFI Delegated Shareholder Litigation against Morris, Nichols, Arsht & Tunnell LLP
  • A filing included hallucinated citations generated with ChatGPT
  • The court imposed a $10,000 monetary sanction
  • Court of Chancery of the State of Delaware, Delaware
  • The order noted the use of ChatGPT was not disclosed to the court
Get Sanctions Watch in your inbox
New AI-citation sanctions, the morning after they hit the docket.