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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
Warned 2025-08-28
The court ordered Cassie D. Preston and Gordon Rees to appear and show cause why sanctions should not be imposed for making filings with AI-fabricated citations.
CASE NO.: 25-30256-CLH JACKSON · Cassie D. Preston; Gordon Rees · U.S. Bankruptcy Court, District of Montana · MT
websitedc.s3.amazonaws.com ↗
The file →
  • CASE NO.: 25-30256-CLH JACKSON involved Cassie D. Preston and Gordon Rees
  • The filing allegedly contained AI-fabricated citations
  • The court issued an order to show cause rather than impose sanctions immediately
  • U.S. Bankruptcy Court, District of Montana
  • August 28, 2025; the page does not name the AI tool or any fake citations
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.
Warned 2025-08-20
IBS Government Services, Inc. filed briefs with fabricated or misquoted GAO cases, and GAO denied the protest on the merits while repeating its warning.
IBS Government Services, Inc. · Government Accountability Office
centrelawgroup.com ↗
The file →
  • IBS Government Services, Inc. faced a GAO warning after filing problematic citations.
  • The filings included fabricated or misquoted GAO cases.
  • GAO denied the protest on the merits but repeated its Raven warning verbatim.
  • Government Accountability Office; federal bid protest forum.
  • Aug. 20, 2025; the decision repeated the sanctions warning.
Caught, not sanctioned 2025-08-19
Wheatley J said AI-generated references were fabricated and misleading and adopted redaction of false case citations.
JML Rose Pty Ltd v Jorgensen · Federal Court of Australia
“There has been an approach, which I will adopt, of redacting false case citations so that such information is not further propagated by AI systems.”
eggernotes.com ↗
The file →
  • JML Rose Pty Ltd v Jorgensen (No 3) in the Federal Court of Australia
  • The court discussed erroneously generated references that were fabricated, fictional, false and fake
  • No sanction amount or sanction was reported on the page
  • Federal Court of Australia, Australia
  • 19 August 2025; Wheatley J said false case citations should be redacted
Caught, not sanctioned 2025-08-19
A trial court order cited four AI-generated non-existent cases, and the High Court refused to set it aside and dismissed the revision.
R.P.No.1658 of 2023 · Andhra Pradesh High Court
“The Court held that an order is not vitiated by the mere inclusion of non-existent AI-generated citations if the legal principles applied to the facts are correct under the law of the land.”

Cases that don't exist

  • Subramani v. M.Natarajan((2013) 14 SCC 95
  • Chidambaram PIllai v. SAL Ramasamy(1071 (2) SCC 68
  • Lakshmi Devi v. K.Prabha((2006) 5 SCC 551

+1 more

lekhanews.in ↗
The file →
  • R.P.No.1658 of 2023 in the Andhra Pradesh High Court
  • Trial court order relied on four AI-generated non-existent citations
  • High Court dismissed the revision; no sanction was imposed
  • Andhra Pradesh High Court, Vijayawada, Andhra Pradesh
  • Decided 2025-08-19; judge accepted the trial judge's explanation and warned to verify sources
Warned AI-assisted legal software 2025-08-19
An unnamed Victorian solicitor filed an AI-generated list of entirely non-existent citations in a family law dispute and had his practising certificate varied.
First-ever Aussie lawyer sanctioned for AI use · Federal Circuit and Family Court of Australia · VIC
““the incident caused significant stress but was unlikely to be repeated.””
lawyersweekly.com.au ↗
The file →
  • Unnamed Victorian solicitor in a family law dispute
  • Submitted AI-generated legal citations that could not be verified
  • Practising certificate varied; no longer a principal lawyer
  • Federal Circuit and Family Court of Australia, Victoria
  • Incident occurred in July 2024; VLSB+C confirmed variation on 19 August 2025
Reprimanded 2025-08-19
A list and summary of AI-generated authorities with inaccurate citations and summaries was tendered to the court and referred to the regulator.
Dayal · Federal Circuit and Family Court of Australia; Victorian Legal Services Board
regulayer.com ↗
The file →
  • In Dayal, a legal professional was sanctioned.
  • An AI-generated list of authorities with inaccurate citations and summaries was tendered.
  • The sanction included practising certificate variation, two years supervised practice, and quarterly reporting.
  • The incident occurred in the Federal Circuit and Family Court of Australia and Victorian Legal Services Board.
  • On 2025-08-19, AI-generated authorities were identified, leading to the only published regulator decision on record.
Reprimanded 2025-08-19
A solicitor was restricted from practicing as a principal or managing trust money after submitting a list of non-existent AI-generated cases.
Victorian Legal Services Board (Mr Dayal) · Mr Dayal · Victorian Legal Services Board
llms-for-lawyers.com ↗
The file →
  • Victorian Legal Services Board (Mr Dayal) involving a Australian solicitor.
  • Solicitor provided a list of fabricated legal decisions generated by an unnamed AI.
  • Barred from practicing as a principal/handling trust funds and placed under two years' supervision.
  • Victorian Legal Services Board (Australia).
  • Dated August 19, 2025; the presiding judge and associates were unable to verify any cited cases.
Referred to the bar 2025-08-19
A solicitor tendered AI-generated authorities with inaccurate citations, resulting in practising restrictions that banned him from operating as a principal.
In re Mr. Dayal · Mr. Dayal · Federal Circuit and Family Court of Australia
corp-intl.com ↗
The file →
  • Solicitor referred to as Mr. Dayal
  • Tendered AI-generated authorities with inaccurate citations and summaries
  • Practising certificate varied to prohibit working as a principal lawyer for two years
  • Victorian Legal Services Board / Federal Circuit and Family Court of Australia
  • August 19, 2025 regulatory action requiring supervised employment
Reprimanded 2025-08-15
Mr Dayal filed AI-generated false citations in a court submission and had his practising certificate varied, barring him from running his own law practice.
Mr Dayal · Mr Dayal · Federal Circuit and Family Court of Australia
ia.acs.org.au ↗
The file →
  • Mr Dayal was penalised after filing fake AI-generated citations in a submission.
  • He admitted he did not verify the contents before filing.
  • His practising certificate was varied, so he cannot act as a principal lawyer or run his own practice.
  • The matter was in the Federal Circuit and Family Court of Australia.
  • The article says the regulator acted in mid-August and the lawyer used AI-based legal software.

Showing 731–740 of 857.

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