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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
Caught, not sanctioned ChatGPT 2025-11-10
Cal State filed a brief with faulty quotes and phantom quotations that an administrative law judge struck from the record.
California State University brief striking order · California State University · California Public Employment Relations Board · CA
“while “there is no proof that AI was, in fact the author” of a Cal State brief, the document “bears all the hallmarks of the hallucinations associated with AI-generated texts” and contains a series of misquotes Cal State failed to explain.”

Cases that don't exist

  • Marshall v. Regis Educational Corporation
laist.com ↗
The file →
  • California State University was the party whose brief was struck.
  • The brief contained faulty quotes and phantom quotations from a 1981 decision.
  • Administrative Law Judge Bernhard Rohrbacher ordered the filing struck from the record.
  • The matter was before the California Public Employment Relations Board in California.
  • CSU later acknowledged the brief had been written with AI assistance.
Fined $2K 2025-11-05
Attorney LeRoy George Siddell filed an opposition with a fake quote and a fabricated citation in a criminal case, and the court sanctioned him $1,500.
People v. Alvarez · LeRoy George Siddell · California Court of Appeal, Division 1, Fourth Appellate District · CA
“The conduct here is not as egregious as what occurred in Noland.”
lanak-hanna.com ↗
The file →
  • In People v. Alvarez, an attorney was sanctioned for filing a brief with fabricated and misquoted authority.
  • The attorney submitted court filings containing fabricated AI authority.
  • The court sanctioned the attorney $1,500 and notified the State Bar.
  • The case was decided in the California Court of Appeal, Fourth Appellate District, Division One.
  • Decided three weeks after Noland v. Land of the Free in 2025.
Caught, not sanctioned AI Overviews 2025-11-04
A lawyer filed material using Google AI Overview that contained fabricated and misrepresented case law, and the court dealt with the AI misuse without listing a sanction.
Choksi v IPS · High Court
damiencharlotin.com ↗
The file →
  • Choksi v IPS involved a lawyer's AI-assisted filing.
  • Google AI Overview was the named source of the fabrications.
  • The entry lists fabricated and misrepresented case law but no sanction.
  • High Court, UK.
  • 4 November 2025; the page names Google AI Overview as the tool.
Fined $5K 2025-11-04
A declaration with fabricated deposition quotations and citations was filed, and Judge Carlton Reeves ordered $5,000 in fees against the lawyer and client.
Pauliah v. Univ. of Miss. Medical Center · Mr. Begley · U.S. District Court for the Southern District of Mississippi · MS
“Manufacturing "facts," then presenting them to the Court as genuine, threatens to corrupt the Court's analysis and undermine the integrity of the judicial process at the summary judgment stage.”
reason.com ↗
The file →
  • Pauliah v. Univ. of Miss. Medical Center; Mr. Begley and Dr. Pauliah were sanctioned.
  • A declaration filed in opposition to summary judgment contained fabricated quotations and manufactured deposition citations.
  • Judge Reeves levied $5,000 total, split $4,000 against Begley and $1,000 against Pauliah.
  • U.S. District Court for the Southern District of Mississippi; federal; Mississippi.
  • Order dated Nov. 4, 2025; the page says Pauliah admitted using generative AI and the court found bad faith.
Reprimanded 2025-11-01
An attorney filed AI-written family-law papers with fake citations; the Kammergericht Berlin reprimanded the lawyer for not reviewing them.
Invented Case Law Citations in Attorney’s Court Filing · Kammergericht Berlin
“As lawyers, they are “obligated” to do so, the court wrote.”
posteo.de ↗
The file →
  • Family-law appeal by a mother seeking custody and court-cost assistance.
  • Attorney filed court documents with citations the court found were obviously written with AI.
  • Kammergericht Berlin reprimanded the attorney.
  • Highest court in Berlin; ruling on a published family-law matter.
  • Decision made in November of the prior year; court said the filing was 'obviously written with the help of AI.'
Outcome unclear 2025-10-30
A pro se litigant submitted filing with fake citations in the D. Colorado court.
Nonnie Berg v. United Airlines, Inc. (1) · D. Colorado · CO
aivortex.io ↗
The file →
  • A pro se litigant in Nonnie Berg v. United Airlines, Inc. (1).
  • The pro se litigant used fake citations.
  • The sanction type and amount are not recorded.
  • The incident occurred in the D. Colorado court, federal jurisdiction, Colorado.
  • The incident date is 2025-10-30, and the case involved fake citations.
Referred to the bar ChatGPT 2025-10-29
Adam Hyman filed an AI-generated divorce brief with fake cases and misquotes, and the Appellate Court of Maryland referred him to the Attorney Grievance Commission.
Mezu v. Mezu · Adam Hyman · Appellate Court of Maryland · MD
“The failure to use AI responsibly in legal research raises ethical issues and can result in sanctions when used improperly. It is unquestionably improper for an attorney to submit a brief with fake cases generated by AI.”
thedailyrecord.com ↗
The file →
  • Adam Hyman was the lawyer referred to the Attorney Grievance Commission.
  • He submitted a divorce brief prepared with ChatGPT that contained fake cases and misquotes.
  • The court imposed a referral to the AGC, with no dollar amount stated.
  • The incident was in the Appellate Court of Maryland in Maryland.
  • The opinion was issued Oct. 29, 2025; Judge Kathryn Graeff said attorneys must verify cited authority.
Fined 2025-10-29
An applicant’s submission used non-existent or irrelevant case law and legislative provisions, and the adjudicator dismissed the application and awarded full costs.
Sky Gardens [2025] QBCCMCmr 373 · Office of the Commissioner for Body Corporate and Community Management · QLD
““If the applicant used AI or other sources in preparing the material they submitted, I am not satisfied they checked the accuracy of the information obtained”.”
qlsproctor.com.au ↗
The file →
  • Sky Gardens [2025] QBCCMCmr 373; the applicant was sanctioned in a body corporate dispute.
  • The submission contained numerous and persistent misrepresentations, including non-existent or irrelevant case law.
  • The adjudicator dismissed the application and awarded full costs to the respondent.
  • Office of the Commissioner for Body Corporate and Community Management, Queensland.
  • 29 October 2025; the adjudicator said the scale of deficiencies amounted to an abuse of process.
Referred to the bar 2025-10-28
Attorney Hale filed a brief with hallucinated case citations; the court found a Rule 11 violation but imposed no fine and ordered notice to clients and future ND Ga. filings.
Selena Boston v. Katt Williams · Loletha Denise Hale · U.S. District Court for the Northern District of Georgia, Atlanta Division · GA
““an overwhelming majority of the cases cited by [the plaintiff’s attorney] either did not exist, did not support the proposition for which they were cited, or misquoted the authority.””
technologylaw.fkks.com ↗
The file →
  • Boston v. Williams; attorney Loletha Denise Hale
  • She filed an opposition brief containing fabricated/hallucinated case authority
  • The court found a Rule 11 violation but did not levy a fine
  • U.S. District Court for the Northern District of Georgia
  • October 28, 2025; the court ordered client notice and 5 years of disclosure in ND Ga. cases

Showing 671–680 of 857.

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