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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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125
Incidents tracked
50
Incidents in 2026
$4,000
In fines, where reported
1 of 125 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 73 of 125 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 19 Copilot 5 AI-assisted legal software 2 ChatGPT-4o 1 Claude 1 CoCounsel 1 Lexis+ AI 1 Strongsuit 1

Counts only incidents where the filing court or the reporting named the tool.

Hall of Shame

All Fined 251 Caught, not sanctioned 199 Warned 125 Referred to the bar 101 Reprimanded 86 Outcome unclear 56 Filing dismissed 37 Suspension 2 Upcoming sanction 1

Showing 81–90 of 125 incidents. Clear filters

Warned 2026-02-13
A lawyer submitted one fabricated case law, leading to a warning.
Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi · 10th Cir. CA
damiencharlotin.com ↗
The file →
  • A lawyer in Martha Liliana Picon-Diaz et al. v. Pamela J. Bondi was sanctioned.
  • The AI misuse involved fabricated case law (1).
  • The sanction was a warning.
  • The court was the 10th Cir. CA, USA.
  • The incident occurred on 2026-02-13; the AI tool was implied.
Warned 2026-02-12
Judge J.P. Boulee sanctioned Atlanta lawyer E. Earle Burke after he filed citations and quotations that did not exist.
E. Earle Burke · E. Earle Burke · U.S. District Court for the Northern District of Georgia · GA
“Salinas said the attorney presented three quotations that did not exist.”
ajc.com ↗
The file →
  • E. Earle Burke was sanctioned in federal court in Georgia.
  • He filed three nonexistent quotations and cited a non-existent case.
  • He must attend a six-hour training course.
  • U.S. District Judge J.P. Boulee imposed the order in the Northern District of Georgia.
  • The article says Magistrate Judge Catherine Salinas questioned whether he used artificial intelligence.
Warned ChatGPT-4o 2026-02-09
The court struck a Stanford professor's expert declaration in its entirety for fabricated citations, an order affirmed by the Eighth Circuit.
Kohls v. Ellison · Jeff Hancock · United States Court of Appeals for the Eighth Circuit · MN
“Rule 11 imposes a “personal, nondelegable responsibility” to ensure the accuracy of everything filed.”
aiforlawyersacademy.com ↗
The file →
  • Kohls v. Ellison
  • A Stanford professor submitted an expert declaration containing fabricated citations
  • The expert declaration was struck in its entirety
  • U.S. Court of Appeals for the Eighth Circuit
  • Affirmed February 9, 2026; established that counsel has a personal duty to validate expert filings
Warned 2026-02-09
A plaintiff's brief contained citations to non-existent cases, and Judge Shah cautioned the plaintiff against continued AI use.
Bettis v. Gaston et al · Northern District of Illinois · IL
tresslerllp.com ↗
The file →
  • Bettis v. Gaston et al was a Northern District of Illinois case.
  • The court found several citations to non-existent cases in the brief.
  • Judge Shah cautioned the plaintiff against continued use of AI.
  • Federal court in Illinois; no monetary sanction was imposed.
  • Feb. 9, 2026; the article says the plaintiff was warned after AI-related fake citations.
Warned 2026-02-09
Mr. Wagner filed a Tax Court brief with three hallucinated AI-generated cases and was let off with a warning.
Peter L. Clinco, Deceased v. Commissioner · Mr. Wagner · United States Tax Court
“A bit of embarrassment for failure to citecheck, failure to ‘fess up, and (if it occurred) use of AI to write a section of the brief is enough for now.”
taishofflaw.com ↗
The file →
  • Peter L. Clinco, Deceased, C. M. Barone-Clinco, Successor in Interest, and C. M. Barone-Clinco; Mr. Wagner was the attorney.
  • He cited four cases; three were hallucinations generated by a large language model AI.
  • Judge Holmes issued only a warning, with no monetary sanction.
  • United States Tax Court; the article says Judge Mark V. Holmes handled it.
  • Filed 2026-02-09; the post says Wagner kept citing the inventions even after IRS counsel objected.
Warned 2026-02-01
In Huynh v. Redis Labs, Gordon Rees allegedly filed another brief with fabricated authority despite earlier sanctions and a warning about possible terminating sanctions.
Huynh v. Redis Labs · Gordon Rees Scully Mansukhani · U.S. District Court (California) · CA
compliancehub.wiki ↗
The file →
  • Gordon Rees Scully Mansukhani was again accused of AI hallucinations.
  • A brief in Huynh v. Redis Labs allegedly contained more fabricated authority.
  • The page says the firm had already received monetary sanctions and a warning.
  • U.S. District Court in California; federal.
  • February 2026; the article says this was a repeat-offender incident.
Warned 2026-01-30
The representative admitted AI-created phantom references after the issue was pointed out, and the court warned him.
PSAHSC v Nursing and Midwifery Council [2026] EWHC 141 · Unregulated Rep, Litigation Friend · High Court of England and Wales
“This was pointed out to him at the hearing.”
naturalandartificiallaw.com ↗
The file →
  • PSAHSC v Nursing and Midwifery Council [2026] EWHC 141 involved an unregulated representative and litigation friend.
  • He used references that the court said were phantoms created by AI.
  • The outcome was a warning.
  • High Court of England and Wales.
  • 30 Jan 2026; he promised not to use AI to generate submissions in future.
Warned ChatGPT 2026-01-29
The appellant used ChatGPT to draft legal submissions and cited cases the tribunal could not locate; the tribunal refused his application and noted possible referral if he were registered.
Folarin v The Immigration Services Commissioner [2026] UKFTT 135 · UK First-tier Tribunal
““This would have had the effect of misleading the Tribunal had the Tribunal not challenged the point.””
naturalandartificiallaw.com ↗
The file →
  • Folarin v The Immigration Services Commissioner; the appellant's submissions
  • He used ChatGPT and other AI tools to find and summarize cases, some of which could not be located
  • No formal sanction, but the tribunal found he was not fit to provide immigration advice
  • UK First-tier Tribunal
  • 2026; tribunal stressed that false citations could mislead and that a future regulator referral was possible
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