legaltech.fyi Beta

Tracker

Sanctions watch

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

Embed this
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 ChatGPT 2024-02-20
A lawyer submitted filings with AI-generated case citations; the BC Supreme Court declined special costs but held her personally liable for other costs.
Zhang v. Chen · counsel in Zhang v. Chen · Supreme Court of British Columbia, Canada · BC
“Citing fake cases in court filings and other materials handed up to the court is an abuse of process and is tantamount to making a false statement … Unchecked, it can lead to a miscarriage of justice.”
corp-intl.com ↗
The file →
  • In Zhang v. Chen, counsel faced sanctions.
  • Two fabricated cases were cited in a parenting time application, with delayed disclosure.
  • Special costs were refused, but costs were ordered personally against counsel.
  • The incident occurred in the Supreme Court of British Columbia, Canada, with Justice Masuhara.
  • On 2024-02-20, ChatGPT was admitted as the source, and counsel was ordered to review other files.
Fined $2K ChatGPT 2024-02-12
Plaintiff's counsel filed opposition memoranda containing four fictitious AI-generated citations and was fined $2,000 under Rule 11.
Smith v. Farwell · Suffolk Superior Court · MA
“two disturbing developments that are adversely affecting the practice of law”
klemchuk.com ↗
The file →
  • Smith v. Farwell involved plaintiff's counsel filing fictitious citations.
  • Counsel filed four memoranda with three containing four fake cases from an AI tool.
  • Court fined counsel $2,000 for Rule 11 violations.
  • Norfolk Superior Court, Massachusetts, presided over by Judge Brian A. Davis.
  • Date: February 2024; judge noted a defense based on ignorance will be less credible.
Referred to the bar ChatGPT 2024-01-30
The Second Circuit referred attorney Jae S. Lee to its grievance panel after he cited a ChatGPT-generated non-existent case in a reply brief.
Park v. Kim · Jae S. Lee · U.S. Court of Appeals for the Second Circuit · NY
“well below the basic obligations of counsel”
mallick.tech ↗
The file →
  • Park v. Kim involved Jae S. Lee of JSL Law Offices.
  • She cited a non-existent case in a reply brief and admitted ChatGPT use.
  • The Second Circuit referred her to its Grievance Panel.
  • U.S. Court of Appeals for the Second Circuit.
  • January 30, 2024; the panel said her conduct was well below the basic obligations of counsel.
Filing dismissed $10K ChatGPT 2024-01-01
A litigant submitted an appellate brief with fictitious AI-generated case citations, and the Missouri Court of Appeals dismissed the appeal and imposed damages.
Kruse v. Karlen · Jonathan Karlen · Missouri Court of Appeals · MO
“The Court of Appeals noted that the “bogus citations” could not, “for any reason….be countenanced and represent a flagrant violation of the duty of candor” owed to the court.”
nysba.org ↗
The file →
  • Kruse v. Karlen involved a self-represented appellant.
  • Her AI program cited 24 cases, but only two were real and both were misunderstood.
  • The court dismissed the appeal and ordered $10,000 in attorney’s fees.
  • Missouri Court of Appeals, Missouri.
  • The article says the AI made up case names and citations that appeared genuine.
Reprimanded 2024-01-01
A lawyer filed a list of authorities that did not exist, and the court varied his practising certificate and imposed supervised practice.
Dayal · Federal Circuit and Family Court of Australia
kennedypartnerslawyers.com.au ↗
The file →
  • Dayal involved a lawyer who submitted a list of authorities to the court that did not exist.
  • The court treated the filing as a serious accuracy failure in court documents.
  • His practising certificate was varied, he could not act as a principal lawyer or handle trust money, and he had to do supervised practice for two years.
  • Federal Circuit and Family Court of Australia.
  • 2024; the article says practitioners remain personally responsible for the accuracy of documents they file.
Reprimanded ChatGPT 2023-11-22
Attorney Zachariah Crabill received a 90-day suspension after filing fabricated ChatGPT citations in a custody case and lying to the judge about their origin.
People v. Crabill · Zachariah C. Crabill · Office of the Presiding Disciplinary Judge of the Supreme Court of Colorado · CO
“In November 2023, a Colorado disciplinary judge approved a suspension of one year and one day, with 90 days to serve, for violations including competence, diligence, and candor to the tribunal.”
advocentral.com ↗
The file →
  • Attorney Zachariah Crabill filed court documents containing fake legal citations.
  • The fake citations were generated using ChatGPT, and Crabill initially blamed an intern.
  • Crabill was suspended for a year and a day, with 90 days served and the rest stayed on probation.
  • Adjudicated by Colorado's presiding disciplinary judge.
  • The disciplinary sanction was handed down in November 2023.
Warned ChatGPT 2023-08-22
The Delhi High Court warned that ChatGPT output cannot be the basis of adjudication and cautioned against fictional case laws and imaginative data.
Christian Louboutin SAS v. M/s The Shoe Boutique-Shutiq · Delhi High Court · DL
“the responses generated by ChatGPT cannot be the basis of adjudication of legal or factual issues in a court of law.”
blog.ipleaders.in ↗
The file →
  • Christian Louboutin SAS v. M/s The Shoe Boutique-Shutiq
  • A party had leaned on ChatGPT in a trademark dispute
  • The court issued a warning, not a money sanction
  • Delhi High Court, Delhi
  • 22 Aug 2023; the court warned against fictional case laws
Fined $10K ChatGPT 2023-06-30
Morris, Nichols, Arsht & Tunnell LLP submitted a brief with hallucinated citations, and the court sanctioned the firm and counsel.
In re: CFI Delegated Shareholder Litigation · Morris, Nichols, Arsht & Tunnell LLP · Court of Chancery of the State of Delaware · DE
““The use of ChatGPT was not disclosed to the Court.””

Cases that don't exist

  • Hsu v. Teco Energy, Inc., 2018 WL 5115675
  • Morris v. 7-Eleven, Inc., 2015 WL 7293045
podcasts.apple.com ↗
The file →
  • In re: CFI Delegated Shareholder Litigation against Morris, Nichols, Arsht & Tunnell LLP
  • A filing included hallucinated citations generated with ChatGPT
  • The court imposed a $10,000 monetary sanction
  • Court of Chancery of the State of Delaware, Delaware
  • The order noted the use of ChatGPT was not disclosed to the court
Warned ChatGPT 2023-06-22
Levidow, Levidow & Oberman P.C. filed a submission with fake citations, and the court warned of sanctions but did not impose one.
Moten v. Apfel · Levidow, Levidow & Oberman P.C · U.S. District Court for the Southern District of New York · NY
““The Court is deeply concerned that a lawyer would submit a brief with citations that do not exist.””

Cases that don't exist

  • Martinez v. Air Line Pilots Ass’n, 2021 WL 4314517
  • Moten v. Apfel, 2023 WL 4001202
podcasts.apple.com ↗
The file →
  • Moten v. Apfel against Levidow, Levidow & Oberman P.C.
  • A filing contained AI-fabricated legal citations
  • The court issued a warning rather than a sanction
  • U.S. District Court for the Southern District of New York, New York
  • The judge said the court was deeply concerned about nonexistent citations

Showing 841–850 of 857.

Get Sanctions Watch in your inbox
New AI-citation sanctions, the morning after they hit the docket.