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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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151
Incidents tracked
26
Incidents in 2026
$542,786
In fines, where reported
50 of 151 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 60 of 151 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 151 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 53 Caught, not sanctioned 32 Warned 19 Referred to the bar 17 Reprimanded 13 Filing dismissed 10 Outcome unclear 6 Suspension 1

Showing 71–80 of 151 incidents involving ChatGPT. Clear filters

Fined $500 ChatGPT
The plaintiff filed AI-prepared pleadings with fictitious legal authorities and was ordered to pay $500 in compensation.
Kalala c. Coopérative d'habitation La Fraternité Micheloise · Superior Court of Québec
lazaruslegal.com ↗
The file →
  • Kalala c. Coopérative d'habitation La Fraternité Micheloise; the plaintiff
  • The pleadings contained fictitious authorities and wrong Civil Code provisions
  • Monetary sanction of $500 in compensation
  • Superior Court of Québec
  • 2025; the plaintiff acknowledged using ChatGPT
Fined $2K ChatGPT 2026-07-31
Attorney Ian G. Gottlieb and his firm, GLG Law, LLC, filed applications for certification to appeal and subsequent briefs containing hallucinated case citations generated by ChatGPT.
TOV Realty, LLC v. Suarez / Kosel Equity, LLC v. MacGregor, 355 Conn. 902 (2026) · Ian G. Gottlieb; GLG Law LLC · Connecticut Supreme Court · CT
“Attorney Gottlieb did not have a dishonest or selfish motive, he cooperated with the disciplinary process by honestly and forthrightly responding to our requests seeking further information and understanding regarding the erroneous citations, he admitted his mistake, he showed sincere contrition, and he has no disciplinary history.”

Cases that don't exist

  • Tov Realty, LLC v. Suarez, 355 Conn. 902 (2026)
  • Kosel Equity v. MacGregor
law360.com ↗
The file →
  • Attorney Ian G. Gottlieb and his firm, GLG Law, LLC, were involved in the cases Tov Realty, LLC v. Suarez and Kosel Equity v. MacGregor.
  • They filed applications for certification to appeal and briefs that contained approximately seven erroneous or unverified citations generated by ChatGPT.
  • Sanctions imposed included 6 additional CLE hours, a $1,000 donation each to the CT Bar Institute, and a compliance report to the Appellate Clerk.
  • The incident occurred in Connecticut's state court system.
  • The court also used the opinion to flag Connecticut’s newly adopted practice rules requiring independent verification of any AI-generated citations or authorities in court filings.
Fined $15K ChatGPT 2026-07-28
Chicago lawyer Mason Cole was fined $15,000 and referred to state disciplinary authorities for filing appellate briefs containing 10 AI-fabricated or misquoted citations.
Scott v. Illinois Human Rights Commission · Mason Cole of Cole Sadkin · Illinois Appellate Court for the First District · IL
“We do not know why attorney Cole feels compelled to rush out obviously flawed filings, but this must stop.”
reason.com ↗
The file →
  • Attorney Mason Cole in Scott v. Ill. Hum. Rts. Comm'n was sanctioned.
  • Cole filed briefs with 10 false citations, including fabricated statutory language and nonexistent case law, after using ChatGPT.
  • The court imposed a monetary fine of $15,000 ($1,500 per false citation) and referred him to the ARDC.
  • The incident occurred in the Appellate Court, First District, Illinois.
  • The sanction was issued on August 13, 2026, with the judge noting that AI-hallucinated citations are no different than false citations created by an attorney's own imagination.
Suspension $10K ChatGPT 2026-07-17
A Toronto lawyer was suspended for six months for using ChatGPT to prepare a factum with AI-hallucinated citations and arguments in a family law matter, and for repeatedly lying to the court and the Law Society of Ontario about her AI use.
Law Society of Ontario v Lee · Mary Hyun-Sook Lee (also known as Jisuh Lee) · Law Society of Ontario Tribunal · ON
“While we are concerned by the lawyer’s reckless reliance on the non-existent cases produced by AI, we are extremely troubled by the lawyer’s subsequent repeated lies to the court and to the law society, which are serious integrity failures.”
lawtimesnews.com ↗
The file →
  • Mary Hyun-Sook Lee, also known as Jisuh Lee, was sanctioned by the Law Society Tribunal.
  • She used ChatGPT to create a factum with AI-hallucinated case citations and arguments, and then lied about using AI to the Ontario Superior Court of Justice and the LSO.
  • She received a six-month license suspension and was ordered to pay the Law Society of Ontario $10,000.
  • The Law Society Tribunal in Ontario handled the case, and contempt of court proceedings were referred to Ontario’s attorney general by Justice Frederick Myers.
  • The sanction order was issued on 2026-07-16, and the tribunal noted her lies to the court and LSO were "serious integrity failures" despite her claims of being unfamiliar with ChatGPT.
Reprimanded ChatGPT 2026-05-21
H. Gregory Harp filed a response with false quotations attributed to real cases and was sanctioned by Judge Harold D. Mooty III.
Jackie Miller v. Regions Bank · H. Gregory Harp · U.S. District Court for the Northern District of Alabama · AL
““Lawyers make errors. Competent and ethical lawyers own them””
findlaw.com ↗
The file →
  • Jackie Miller v. Regions Bank; attorney H. Gregory Harp
  • Harp filed a response with false quotations in support of summary judgment briefing
  • He was sanctioned and suspended for six months in the Northern District of Alabama
  • U.S. District Court for the Northern District of Alabama, Alabama
  • May 21, 2026; the court suspected generative AI and Harp later admitted using free ChatGPT for proofreading
Warned ChatGPT 2026-05-05
Kelly Guagenty filed a brief with AI-caused citation errors, mischaracterizations and an improper quotation; Judge Stacey D. Neumann ordered AI training and new safeguards but no fine.
Jessica Fuller v Hyde School · Karen Guagenty · U.S. District Court for the District of Maine · ME
“Although AI can be a useful aid in research and drafting, its use does not diminish an attorney's nondelegable duties of diligence, candor, and reasonable inquiry.”
habeas.ai ↗
The file →
  • FULLER v. HYDE SCHOOL involved Attorney Kelly Guagenty.
  • She submitted two filings with AI-generated erroneous legal citations.
  • The court imposed non-monetary sanctions.
  • United States District Court for the District of Maine, Maine.
  • May 5, 2026; counsel said the AI used was either Claude or ChatGPT.
Caught, not sanctioned ChatGPT 2026-04-18
Sullivan & Cromwell filed an emergency motion with AI hallucinations and inaccurate citations, then apologized and corrected the filing before any sanctions order.
In re Prince Global Holdings Limited, et al. · Sullivan & Cromwell LLP · U.S. Bankruptcy Court, Southern District of New York · NY
“"Hallucinations" are instances in which artificial intelligence tools fabricate case citations, misquote authorities, or generate non-existent legal sources,”
reuters.com ↗
The file →
  • Prince Global Holdings bankruptcy matter; Sullivan & Cromwell was the firm involved.
  • A filing contained inaccurate citations and other errors, including AI hallucinations.
  • No sanction is reported; the firm apologized and said it would correct the filing.
  • The matter was in Manhattan before Chief Judge Martin Glenn.
  • On 2025-04-18, partner Andrew Dietderich wrote the judge; the errors were caught by Boies Schiller Flexner.
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