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

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199
Incidents tracked
40
Incidents in 2026
$11,578
In fines, where reported
3 of 199 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 75 of 199 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 32 Gemini 4 Claude 2 Perplexity AI 2 AI Overviews 1 ChatGPT-4o 1 ChatOn 1 Eve 1 Grammarly 1 MX2.law 1 OpenCase 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

Showing 41–50 of 199 incidents. Clear filters

Caught, not sanctioned
Frederick Knack filed a brief citing a nonexistent Minnesota case and other fake cases generated by AI; the court caught the hallucinations.
State by Sunquist versus Provost · Frederick Knack · Hennepin County Court · MN
“the court wonders if this citation may be the result of an AI generated hallucination”
wral.com ↗
The file →
  • Frederick Knack was the Minnesota attorney named in the filing.
  • He cited a nonexistent 1992 case and other cases after using AI without checking them.
  • The article reports no sanction in this incident.
  • Hennepin County Court in Minnesota was the venue.
  • Judge Lourie Miller said the citation may have been an AI generated hallucination.
Caught, not sanctioned
Three lawyers faced possible career-ending action after AI-generated fake case citations were discovered in a Family Court custody battle.
King's Counsel disciplinary action · Family Court
adelaidenow.com.au ↗
The file →
  • Three lawyers were the subject of the reported action.
  • AI-generated fake case citations were discovered in a custody battle.
  • The reported outcome was possible career loss, not a stated sanction order.
  • The court was Family Court.
  • The article gives no date, judge, tool, or citation strings.
Caught, not sanctioned
A Melbourne law firm filed court documents containing citations fabricated by generative AI.
Melbourne firm busted using AI-fabricated citations · A Melbourne law firm · Court not specified · VIC
lawyersweekly.com.au ↗
The file →
  • A Melbourne law firm was caught using AI-fabricated citations.
  • The page says court documents contained fabricated citations made by generative AI.
  • No sanction amount or type is stated on the page.
  • The matter is described as Melbourne-based and in court.
  • Published Dec. 31, 2025; no tool or judge quote is given.
Caught, not sanctioned
A lawyer cited nonexistent cases in court after an AI tool hallucinated legal authorities, and the page says he faced serious professional consequences.
Harringey LBC matter · a lawyer at Harringey LBC
legalfly.com ↗
The file →
  • A lawyer at Harringey LBC was involved
  • He cited cases in court that didn't exist
  • The AI hallucinated plausible-sounding citations
  • The page says he faced serious professional consequences
  • The article gives no court, date, sanction amount, or tool name
Caught, not sanctioned
Annapolis officials were accused in a federal class action of filing a motion with at least one fake case and phantom quotations, but no sanction had been imposed on the page.
Annapolis City Attorney D. Michael Lyles · D. Michael Lyles · U.S. District Court · MD
“Plaintiffs cannot be sure, but the motion’s inclusion of fabricated citations and quotations are hallmarks of an AI generated motion with ‘hallucinations,’”
thedailyrecord.com ↗
The file →
  • Annapolis City Attorney D. Michael Lyles was named on the page.
  • Plaintiffs alleged the city's motion to decertify cited at least one nonexistent case and misquoted others.
  • The page reports no sanction yet; it says Lyles left the job after the accusation.
  • The matter is described as a federal class-action lawsuit concerning public housing in Maryland.
  • The page says the filing appeared to be an AI-generated motion with 'hallucinations'.
Caught, not sanctioned ChatGPT
Counsel was said to have filed a letter brief with fabricated AI citations, and Judge Ruth Bermudez Montenegro dismissed the case for lack of diversity jurisdiction.
LaPaglia v. Valve Corp. · S.D. Cal. · CA

Cases that don't exist

  • Bassett's Adm'r v. Cunningham's Adm'r, 50 Va. 684
reason.com ↗
The file →
  • LaPaglia v. Valve Corp. involved petitioner's counsel.
  • Valve said counsel submitted a letter brief with AI-fabricated citations.
  • Judge Ruth Bermudez Montenegro dismissed the case for lack of diversity jurisdiction.
  • S.D. Cal., federal court in California.
  • The page says the counsel had been recently sanctioned by an arbitrator; ChatGPT was used only in a law-clerk check.
Caught, not sanctioned
Kaʻōnohiokalā J. Aukai IV filed a brief with six flawed citations, including two fabricated ones, and Circuit Judge Kelsey Kawano accepted his apology and imposed no sanctions.
Kaʻōnohiokalā J. Aukai IV case · Kaʻōnohiokalā J. Aukai IV · Hawaiʻi Circuit Court · HI
civilbeat.org ↗
The file →
  • Kaʻōnohiokalā J. Aukai IV was the lawyer named in the article.
  • He filed a brief where all six citations were flawed, including two completely fabricated.
  • Judge Kelsey Kawano accepted the apology and declined sanctions.
  • Hawaiʻi Circuit Court, state of Hawaiʻi.
  • December 17, 2025; Aukai said the flaws were the result of AI hallucinations.
Caught, not sanctioned
Mark Valencia filed a brief with a non-existent case and a misstated Hawaiʻi Supreme Court decision; Judge Jordon Kimura found a Rule 11 violation and said he would sanction him later.
Valencia case · Mark Valencia · Hawaiʻi Circuit Court · HI
civilbeat.org ↗
The file →
  • Mark Valencia was the lawyer criticized in Hawaiʻi Circuit Court.
  • He submitted a brief with a fake case and a misstated Hawaiʻi Supreme Court decision.
  • Judge Kimura found a Rule 11 violation but had not yet set the sanction.
  • Hawaiʻi Circuit Court, state of Hawaiʻi.
  • December 17, 2025; Valencia blamed his associate and said the citations were AI-generated hallucinations.
Caught, not sanctioned
A relator’s legal team filed an expert report with fake citations and fabricated testimony, and the defendants sought sanctions and disqualification.
In re the relator’s legal team · U.S. District Court for the District of Utah · UT
“"The liability for using these new technologies without proper supervision falls squarely on the attorney. AI is a powerful tool, but it lacks professional judgment and a duty of candor to the court. Attorneys must remain the final check, or they will be held accountable for the errors it produces."”
qpwblaw.com ↗
The file →
  • A relator’s legal team in a Utah federal case
  • An expert report contained AI-generated falsehoods, including fake citations and fabricated testimony
  • The defendants moved for sanctions and disqualification; the article says the court permitted withdrawal but did not dismiss the issue
  • U.S. District Court for the District of Utah
  • No date was given; the article attributes the misconduct to a generative AI tool and alleges willful blindness
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