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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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53
Incidents tracked
12
Incidents in 2026
$280,119
In fines, where reported
44 of 53 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 23 of 53 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 53 Claude 4 Lexis+ AI 4 Westlaw Precision 4 CoCounsel 3 Copilot 2 AI-assisted legal software 1 Archie 1 ChatOn 1 ClearBrief 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 Gemini 1 Ghostwriter Legal 1 Google AI 1 Google Scholar 1 Grok 1 Irys 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 1–10 of 53 incidents involving ChatGPT. Clear filters

Fined $3K ChatGPT
Walters filed papers with hallucinated citations; the court sanctioned him for the fake authorities.
Park v. Kim · Mark Walters · U.S. District Court, Southern District of New York · NY
“The opinion is short and direct.”

Cases that don't exist

  • Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014)
aiunderstanding.org ↗
The file →
  • Park v. Kim; Mark Walters was sanctioned
  • He filed briefs containing hallucinated legal citations
  • $3,000 monetary fine
  • U.S. District Court, Southern District of New York, New York
  • The page links the misconduct to ChatGPT-generated fake citations
Fined $5K ChatGPT 2026-09-14
Attorney Stephen D. Aarons was held in direct contempt and fined $5,000 after using ChatGPT to draft a murder appeal that contained fabricated witnesses and testimony.
State v. Samuel J. Garcia · Stephen D. Aarons · New Mexico Supreme Court · NM
“So either you have buried your head in the sand ... and that’s an intentional choice to be uninformed, or you took a gamble, and neither of those are consistent with the code of conduct.”
yahoo.com ↗
The file →
  • Attorney Stephen D. Aarons was sanctioned by the court in connection with his representation of Oscar Renee Sandoval.
  • Aarons used ChatGPT to draft an appeal brief that fabricated four witnesses, invented testimony, and misrepresented legal authorities.
  • The court held Aarons in direct contempt, fined him $5,000, struck his briefs, barred him from appearing, and referred him to the Disciplinary Board.
  • The decision was handed down by the New Mexico Supreme Court in Santa Fe, New Mexico.
  • The sanction order was issued on September 9, 2026, after Aarons acknowledged relying on ChatGPT output without verifying it against the record.
Fined $1K ChatGPT
The 10th Circuit ordered attorney Kusmin Linda Amarsingh to pay $1,000 for submitting a legal filing containing fake case citations generated by ChatGPT.
Kusmin Linda Amarsingh · Kusmin Linda Amarsingh · U.S. Court of Appeals for the 10th Circuit · CO
coloradopolitics.com ↗
The file →
  • Attorney Kusmin Linda Amarsingh submitted fake case citations generated by artificial intelligence.
  • The attorney used unverified citations generated by ChatGPT in a legal filing.
  • The court ordered the lawyer to pay $1,000 to the opposing side as a financial penalty.
  • The sanction was ordered by the U.S. Court of Appeals for the 10th Circuit in Denver.
  • The three-judge panel noted that the attorney had expressed remorse for relying on the tool.
Fined $1K ChatGPT
Richard Bednar filed a brief with fake ChatGPT-generated citations, and the Utah Court of Appeals sanctioned him.
Richard Bednar · Richard Bednar · Utah Court of Appeals · UT
“"here is this case and it supports our position" and the case doesn’t exist.”

Cases that don't exist

  • Royer v. Nelson
  • Wadsworth v. Walmart
  • United States v. Hayes
legal.thomsonreuters.com ↗
The file →
  • Richard Bednar was sanctioned in the Utah Court of Appeals matter.
  • He submitted a brief with fake citations generated by ChatGPT.
  • He was ordered to pay fees, refund client fees, and donate $1,000.
  • Utah Court of Appeals in Utah.
  • The brief included the non-existent case Royer v. Nelson.
Fined $3K ChatGPT 2026-08-18
The court excluded an expert report after previously fining plaintiff's counsel $3,000 for relying on dozens of ChatGPT and Claude AI-fabricated citations.
Joann LeDoux v. Outliers, Inc. · Jocelyn Stewart · U.S. District Court for the Western District of Washington · WA
“The court concluded that the expert’s “multiple hallucinated citations ‘shatter … his credibility with this Court.’””
nwsidebar.wsba.org ↗
The file →
  • LeDoux v. Outliers, Inc. involved unnamed plaintiff's counsel.
  • Counsel used ChatGPT and Claude to build a citation table containing dozens of inaccurate citations across five filings.
  • The court fined counsel $3,000 under Rule 11 and later excluded an expert's report entirely.
  • The case was heard in the U.S. District Court for the Western District of Washington (Tacoma).
  • Judge Tiffany M. Cartwright excluded the expert report on August 18, 2026, following the July fine.
Fined $2K ChatGPT
Cathleen Siebrecht filed a brief with AI-hallucinated citations and the court sanctioned her.
In re Cathleen Siebrecht · Cathleen Siebrecht · U.S. District Court for the Middle District of Florida · FL
“I absolve the mother of any intention to mislead the court.”

Cases that don't exist

  • Johnson v. City of Detroit, 2024 WL 1234567
peaceforasia.ch ↗
The file →
  • In re Cathleen Siebrecht; attorney Cathleen Siebrecht was sanctioned.
  • She filed a brief containing AI-hallucinated citations.
  • The court imposed a $2,500 monetary fine.
  • U.S. District Court for the Middle District of Florida; federal court in Florida.
  • Date not given on the page; the page links this as an AI hallucination case.
Fined $5K ChatGPT
Jan Tomasik and Daniel Mann filed a brief with bogus citations generated by ChatGPT, and Judge Hardy ordered them removed, referred to the Nevada bar, and fined.
Uprise · Jan Tomasik; Daniel Mann; Cozen O’Connor · Washoe County, Nev., District Court · NV
“This is larger than any of us,”
lawnext.com ↗
The file →
  • Uprise; Jan Tomasik, Daniel Mann, and Cozen O’Connor
  • They filed a brief with bogus legal references generated by ChatGPT.
  • Judge Hardy ordered removal, bar referral, and $2,500 fines each ($5,000 total), then suspended them.
  • Washoe County, Nevada, District Court in Washoe County, Nev.
  • Last May; Hardy said he wanted system improvement and redemption.
Fined $10K ChatGPT
A California attorney filed ChatGPT-generated fake case quotes and citations, and the state appeals court fined the lawyer $10,000.
California attorney sanctioned for ChatGPT-generated fake case quotes and citations · state appeals court · CA
ai.plainenglish.io ↗
The file →
  • A California attorney was sanctioned for ChatGPT-fabricated case quotes.
  • The lawyer submitted 21 of 23 quotes that ChatGPT had completely fabricated.
  • The court fined the lawyer $10,000.
  • The sanction came from a state appeals court in California.
  • The page names ChatGPT as the source of the fake citations.
Fined $10K ChatGPT
Two law firms faced sanctions after submitting ChatGPT-generated briefs that contained nine fabricated citations out of 27 total authorities.
ChatGPT-generated briefs
proplaintiff.ai ↗
The file →
  • Two law firms were sanctioned for ChatGPT-generated briefs.
  • Their filings contained nine fabricated citations out of 27 authorities.
  • The page says the sanction was a $10,000 wake-up call.
  • The court and judge are not named on the page.
  • The article gives the fabrication count but no citation strings.
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