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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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10
Incidents tracked
2
Incidents in 2026
$95,567
In fines, where reported
2 of 10 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 7 of 10 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 10 Centient AI 1 LegalAI 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 1–10 of 10 incidents involving ChatGPT. Clear filters

Filing dismissed ChatGPT
A worker filed AI-generated WCAT submissions with fabricated cases and policies; WCAT dismissed the appeal and warned of possible costs.
A2501051, 2025 CanLII 97422 · British Columbia Workers’ Compensation Appeal Tribunal
“It appears that the worker’s submission was created, at least partly, with the use of artificial intelligence.”

Cases that don't exist

  • Zhang v. Chen, 2024 BCSC 285
  • Geismayr v. The Owners, Strata Plan KAS 1970, 2025 BCCRT 217
  • AQ v. BW, 2025 BCCRT 907

+1 more

wcblawyers.com ↗
The file →
  • A2501051 at WCAT involved a worker's submission.
  • The worker used AI to prepare arguments for a prohibited action appeal.
  • The submission contained fake cases, incorrect policy, and bad legal arguments.
  • WCAT dismissed the appeal and noted AI-based submissions can lead to costs.
  • The deputy registrar said the submission was partly created with artificial intelligence and cited hallucinated cases.
Filing dismissed ChatGPT 2026-02-06
Kenosha County Judge David Hughes sanctioned DA Xavier Solis and dismissed two criminal cases after Solis filed a response containing hallucinated AI case citations.
State v. Solis · Xavier Solis · Kenosha County Circuit Court · WI
“Hughes struck Solis’ written response after finding it used AI without disclosure and relied on “hallucinated,” false legal citations.”
yahoo.com ↗
The file →
  • Kenosha County DA Xavier Solis was sanctioned by Judge David Hughes.
  • Solis filed a brief riddled with hallucinated and bogus AI-generated case citations.
  • The court sanctioned Solis and dismissed two open criminal cases.
  • The proceedings occurred in Kenosha County Circuit Court, Wisconsin.
  • The sanction occurred in February after defense attorneys flagged fake citations in a motion reply.
Filing dismissed ChatGPT 2026-02-05
Defense counsel filed a motion-to-dismiss brief with false citations, then repeated the errors after a sanctions order to show cause; the court struck the filings and entered default judgment.
Flycatcher Corp. Ltd. v. Affable Ave. LLC · Steven A. Feldman · U.S. District Court for the Southern District of New York · NY
“Only 14 out of 60 cases were hallucinations.”

Cases that don't exist

  • 2022 WL 4637582
  • 2024 LEXIS 2847243
nysba.org ↗
The file →
  • Flycatcher v. Affable Avenue involving attorney Steven A. Feldman
  • Repeatedly submitted AI-generated fake citations and false quotes in bad faith
  • Briefs struck and default judgment entered against client
  • U.S. District Court for the Southern District of New York
  • Decided February 5, 2026; tools used included NotebookLM, vLex, and Paxton AI
Filing dismissed ChatGPT 2025-11-14
A pro se filer used AI-generated citations in a bankruptcy filing; the court sanctioned her by dismissing the case without prejudice.
In re Cathleen Siebrecht · Cathleen Siebrecht · U.S. Bankruptcy Court, Eastern District of Virginia · VA
““The ‘AI-generated citations’ in the filing were ‘hallucinated’ and not supported by the law.””

Cases that don't exist

  • In re Zepeda, 2023 Bankr. LEXIS 1234
  • In re Jones, 2024 WL 1234567
calawyers.org ↗
The file →
  • In re Cathleen Siebrecht involved Cathleen Siebrecht, who filed a bankruptcy paper with AI-generated citations.
  • The filing contained hallucinated legal citations and the court found they were unsupported by law.
  • The court dismissed the case without prejudice.
  • It was in the U.S. Bankruptcy Court for the Eastern District of Virginia.
  • The order was entered on 2025-11-14, and the page says the citations were ChatGPT-generated.
Filing dismissed ChatGPT 2025-09-30
A relator disclosed an expert report with generative-AI hallucinations, and the federal judge dismissed the FCA suit after related sanctions motions were filed.
U.S. ex rel. Khoury v. Intermountain Healthcare Inc et al. · Gary Giampetruzzi, Jessica R. Montes and Vanna Mavromatis · U.S. District Court for the District of Utah · UT
paulhastings.com ↗
The file →
  • U.S. ex rel. Khoury v. Intermountain Healthcare Inc et al. involved relator-side counsel and an expert report.
  • The report contained generative AI hallucinations, including bogus deposition testimony and fictitious quotes from government manuals.
  • On 2025-09-30, the federal judge granted the United States’ motion to intervene and dismiss the case.
  • The case was dismissed with prejudice to the relator and without prejudice to the United States.
  • District of Utah; the article does not name the AI tool, but says the expert used a generative AI tool and the parties had motion practice over sanctions.
Filing dismissed ChatGPT 2025-09-25
Oready, LLC filed protest briefs with fabricated, mismatched, and misquoted GAO citations, and GAO dismissed the protests as an abuse of process.
Oready, LLC · Government Accountability Office
“Our decision here is not based on the use of AI as a method of research; it is based on the protester’s repeated reliance on non-existent citations or decisions without verifying their correctness and applicability to the arguments being presented.”
centrelawgroup.com ↗
The file →
  • Oready, LLC was dismissed after filing AI-tainted protest briefs.
  • The filings included fabricated GAO decisions, mismatched citations, and misquoted holdings.
  • GAO dismissed the protests as an abuse of process.
  • Government Accountability Office; federal procurement protest forum.
  • Sept. 25, 2025; GAO said the issue was unverified non-existent citations, not AI use itself.
Filing dismissed $86K ChatGPT 2025-08-01
Lawyer James Martin Paul filed briefs with hallucinated AI citations in ByoPlanet cases; the court dismissed the federal matters, awarded fees, and referred him to the Florida Bar.
ByoPlanet International v. Johansson and Gilstrap · James Martin Paul · Southern District of Florida · FL
“When he argued the fine was too high, the court shot back that caving to his arguments “would only benefit serial hallucinators.””
relativity.com ↗
The file →
  • ByoPlanet Int’l, LLC v. Johansson and related matters; attorney James Martin Paul
  • Paul used hallucinated citations across eight matters and even filed fabricated quotations after being put on notice
  • Judge Leibowitz dismissed the four federal matters without prejudice and without leave to amend, awarded fees and costs, and referred Paul to the Florida Bar
  • U.S. District Court for the Southern District of Florida, Florida
  • July 17, 2025; Paul told the court he and his paralegal used ChatGPT
Filing dismissed ChatGPT 2025-04-01
An applicant repeatedly used the term "subornation of perjury," which Judge David Nolan said sounded like AI and denied the judicial review appeal.
Judicial review appeal in Ireland · High Court
“This sounds like something that derived from an artificial intelligence source,”
businessplus.ie ↗
The file →
  • An unnamed applicant was before Judge David Nolan.
  • The applicant repeatedly used a phrase the judge thought came from AI.
  • Judge Nolan denied the judicial review appeal.
  • This happened in the High Court in Ireland.
  • About four months after Dec. 2024; Nolan said it had the hallmarks of ChatGPT or a similar tool.
Filing dismissed ChatGPT 2025-01-01
The court dismissed a damages claim after the plaintiff's ChatGPT-assisted complaint relied on inaccurate or non-existent legal bases.
AI-written lawsuit dismissed by the court · Sąd Okręgowy we Wrocławiu
“the statement of claim having been drafted entirely with the assistance of ChatGPT.”
konbriefing.com ↗
The file →
  • AI-written lawsuit dismissed by the court; the plaintiff
  • The complaint was drafted entirely with ChatGPT and used inaccurate or non-existent legal bases
  • The court dismissed the claim as unfounded
  • Wrocław, Poland
  • 2025; the court said responsibility for the content rested with the plaintiff
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.
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