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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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857
Incidents tracked
266
Incidents in 2026
$2,397,608
In fines, where reported
212 of 857 report an amount

The curve

Incidents per month

Last 18 months of published incidents, by the date of the court's order.

May 2025 Oct 2026

Charting 447 of 857 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 249 Caught, not sanctioned 198 Warned 124 Referred to the bar 101 Reprimanded 86 Outcome unclear 57 Filing dismissed 39 Suspension 2 Upcoming sanction 1
Fined Google AI 2025-12-18
The court struck an opposition containing two fictitious cases and eight mischaracterized citations and ordered counsel to pay opposing attorney fees.
Zhang v. National Public Radio, Inc. · U.S. District Court for the District of Columbia · DC
midwestfrontier.ai ↗
The file →
  • Zhang v. National Public Radio, Inc. involved multiple AI-related citation errors
  • Counsel filed an opposition brief with two fictitious cases and eight mischaracterized citations
  • The court struck the brief and ordered counsel to pay NPR's reply drafting fees
  • Decided in the U.S. District Court for the District of Columbia
  • Order issued on December 18, 2025
Caught, not sanctioned 2025-12-17
A brief cited fake cases, and Judge Johnston did not impose sanctions, likely because the litigant was pro se.
In Halpern v. FRB of N.Y. · Northern District of Illinois · IL
tresslerllp.com ↗
The file →
  • In Halpern v. FRB of N.Y. involved fake-case citations.
  • The court received a brief citing fake cases but imposed no sanctions.
  • The article says leniency was likely due to the pro se litigant.
  • Northern District of Illinois, federal court in Illinois.
  • Dec. 17, 2025; Judge Johnston was one of the judges mentioned.
Fined $6K 2025-12-16
Blackburn filed a response brief with hallucinated AI-generated case law; Judge Leo Gordon fined him and ordered bar notifications.
Liza Gardner v. Sean "Diddy" Combs · Tyrone Blackburn · U.S. District Court for the Southern District of New York · NY
“"Mr. Blackburn confirmed that he indeed used AI that provided him with hallucinated case law and propositions that he then incorporated into his response brief and that he failed to verify on subsequent review," Judge Gordon wrote.”
billboard.com ↗
The file →
  • Liza Gardner v. Sean "Diddy" Combs; attorney Tyrone Blackburn was sanctioned.
  • He used AI and cited hallucinated case law in a response brief.
  • Judge Gordon imposed a $6,000 fine and required bar notifications.
  • U.S. District Court for the Southern District of New York.
  • Dec. 16 ruling; Blackburn admitted the AI mistakes and the case "Masha" did not exist.
Caught, not sanctioned 2025-12-15
The court found the reopening request relied on non-existent case law, likely from uncontrolled AI use, and treated the conduct as bad faith and disruptive.
Ondernemingsrechtbank Gent, ECLI:BE:ORGNT:2025:JUG.20251215.1 · Ondernemingsrechtbank Gent
konbriefing.com ↗
The file →
  • Ondernemingsrechtbank Gent; the company
  • The reopening request cited non-existent case law likely produced by uncontrolled AI
  • The court found bad faith and disruption but imposed no stated sanction
  • Ghent, Belgium
  • 2025-12-15; insolvency proceedings before the commercial court
Warned 2025-12-15
Garcia appealed with fabricated legal citations made by generative AI, and PERB affirmed dismissal but declined monetary sanctions.
Atwater Elementary Teachers Association, CTA/NEA (Garcia) · Christina Garcia · California Public Employment Relations Board · CA
perb.ca.gov ↗
The file →
  • Atwater Elementary Teachers Association, CTA/NEA (Garcia) and Christina Garcia
  • Garcia’s appeal contained fabricated legal citations created by generative AI tools
  • PERB affirmed dismissal and declined monetary sanctions
  • California Public Employment Relations Board, California
  • 2025-12-15; PERB warned that fabricated citations in filings will bring serious consequences
Reprimanded 2025-12-12
In an injunction proceeding, the judge suspected an appeal brief was drafted using AI and admonished the lawyer after declaring the appeal void.
La IA también alucina con leyes · Court in the Argentine province of Salta
“She admonished the lawyer, stating that while the use of Artificial Intelligence is not prohibited, the lawyer remains fully responsible for the content.”
konbriefing.com ↗
The file →
  • La IA también alucina con leyes; the lawyer
  • A brief in an injunction proceeding contained serious inconsistencies and was suspected to be AI-drafted
  • The judge admonished the lawyer and declared the appeal void
  • Salta, Argentina
  • 2025-12-12; the appeal was declared desierta
Fined $3K ChatGPT 2025-12-12
Co-counsel Celeste Boyd used ChatGPT to draft and edit portions of briefs in an OnlyFans-related case and was sanctioned $3,000 for failing to verify them.
Celeste Boyd · Celeste Boyd · U.S. District Court for the Central District of California · CA
“The judge additionally imposed a $3,000 sanction on co-counsel Celeste Boyd, who he said used ChatGPT to draft and edit portions of the briefs but failed to verify the material, Reuters also reports.”
abajournal.com ↗
The file →
  • Celeste Boyd was sanctioned as co-counsel in the OnlyFans case.
  • She used ChatGPT to draft and edit portions of briefs that contained hallucinated material.
  • The court imposed a $3,000 sanction on Boyd.
  • U.S. District Court for the Central District of California; Judge Fred Slaughter; California.
  • The article says she failed to verify the material before filing.
Warned Copilot 2025-12-11
Dana McClain filed a pleading with AI-generated citations that could not be verified, and the Arkansas Supreme Court issued a show-cause order.
Dana McClain · Dana McClain · Arkansas Supreme Court · AR
“In its order, the Supreme Court reminded attorneys they are responsible for the accuracy of all filings and warned that misuse of artificial intelligence in legal work could result in discipline, including substantial fines, suspension or loss of the privilege to practice law in Arkansas.”
ktlo.com ↗
The file →
  • Dana McClain was the Arkansas attorney involved.
  • She filed court documents containing AI-generated citations that could not be verified.
  • The Arkansas Supreme Court issued a show-cause order; the article does not report a monetary sanction.
  • Arkansas Supreme Court, Arkansas.
  • Dec. 11, 2025; she said she used Microsoft Office Copilot to draft the response and failed to verify the citations.
Caught, not sanctioned ChatGPT 2025-12-10
A pro se claimant used ChatGPT to generate fabricated case law, and the tribunal awarded a preparation time order of £2,178 stayed pending appeal.
Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy · Employment Tribunals (Leeds)
damiencharlotin.com ↗
The file →
  • Mr J Harrison v Mr D May t/a Leeds Gymnastics Academy involved AI-generated citations.
  • ChatGPT generated fabricated case law in the pleadings.
  • The tribunal awarded a preparation time order of £2,178, stayed pending EAT appeal.
  • Employment Tribunals (Leeds), UK.
  • 10 December 2025; the page says the payment was stayed pending appeal.
Referred to the bar 2025-12-10
Sara Evelyn McLane filed an answer brief with three inaccurate AI-generated citations and was referred to The Florida Bar for possible sanctions.
Russell v. Mells · Sara Evelyn McLane · Florida Second District Court of Appeal · FL
“To state the obvious, it is a fundamental duty of attorneys to read the legal authorities they cite in appellate briefs or any other court filings to determine that the authorities stand for the propositions for which they are cited.”

Cases that don't exist

  • Cade v. Roberts
news.bloomberglaw.com ↗
The file →
  • Russell v. Mells involved attorney Sara Evelyn McLane.
  • She filed an answer brief with inaccurate computer-generated citations, including one nonexistent case.
  • The court referred her to The Florida Bar; no monetary sanction was imposed in the article.
  • Florida Second District Court of Appeal in Florida.
  • Dec. 10, 2025; Chief Judge Matthew C. Lucas said counsel must personally execute the written response.

Showing 621–630 of 857.

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