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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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17
Incidents tracked
0
Incidents in 2026
$100,000
In fines, where reported
1 of 17 report an amount

The curve

Incidents per month

Last 18 months of published incidents, by the date of the court's order.

Mar 2025 Aug 2026

Charting 10 of 17 incidents — the rest are undated or fall outside this window.

Blamed by name

ChatGPT 17 Claude 2 LEAP 2 AI-based legal software 1 Copilot 1 GPT-3.5 1

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

Hall of Shame

All Fined 58 Caught, not sanctioned 42 Warned 21 Referred to the bar 17 Filing dismissed 8 Reprimanded 7 Outcome unclear 2 Suspension 1

Showing 17 incidents involving ChatGPT. Clear filters

Referred to the bar ChatGPT
A lawyer was referred to a disciplinary regulator after filing two documents that relied on non-existent citations and quotes.
ChatGPT blunder sees lawyer referred to regulator · Disciplinary regulator
lawyersweekly.com.au ↗
The file →
  • A lawyer was referred to a disciplinary regulator.
  • The page says two filed documents relied on non-existent citations and quotes.
  • The sanction was referral; no amount is stated.
  • The article names ChatGPT as the AI tool.
  • Published Dec. 31, 2025; the page gives no case caption or judge quote.
Referred to the bar ChatGPT
Two judicial review applications contained false case citations generated by non-specialist AI tools, and the Tribunal warned that supervisors and signatories risk referral.
R (on the application of Munir) v Secretary of State for the Home Department · Upper Tribunal (Immigration and Asylum Chamber)
“Legal professionals are obliged to ensure that legal arguments which are presented to the First-tier Tribunal or Upper Tribunal are factually and legally accurate.”
ein.org.uk ↗
The file →
  • R (on the application of Munir) v Secretary of State for the Home Department involved two judicial review applications.
  • The grounds and supporting material contained false and non-existent case citations from AI drafting.
  • The Tribunal warned failures to check work are likely to result in referral to the SRA or another regulator.
  • Upper Tribunal (Immigration and Asylum Chamber), UK.
  • Published 2026-02-20; the page says ChatGPT was one open-source AI tool discussed.
Referred to the bar ChatGPT
A solicitor submitted a filing with a fake case name and false citations; the Upper Tribunal said it would have referred him to regulators but for his self-reporting.
Tahir Mehmood Mohammed · Tahir Mehmood Mohammed · Upper Tribunal, Immigration and Asylum Chamber
“It matters not how such citation errors come about.”
legalfutures.co.uk ↗
The file →
  • Tahir Mehmood Mohammed, a solicitor at TMF Immigration Lawyers, filed false citations.
  • He said he may have used Google AI mode and had also put client material into ChatGPT.
  • The tribunal would have referred him to the IAA and SRA but for self-reporting.
  • Upper Tribunal, Immigration and Asylum Chamber; judge Fiona Lindsley.
  • November 2025 decision, published on 24 February 2026; the judge said errors matter regardless of whether they came from a trainee or ChatGPT.
Referred to the bar ChatGPT 2025-12-04
Jisuh Lee filed a factum with hallucinated case law and allegedly lied about using ChatGPT; the court referred the matter for criminal contempt proceedings.
Ko v. Li · Jisuh Lee of ML Lawyers · Ontario Superior Court of Justice
““This is a very unusual case and one that may resonate throughout the administration of justice.””
law360.ca ↗
The file →
  • Ko v. Li involved Jisuh Lee of ML Lawyers in an estate matter.
  • She filed a factum containing AI-hallucinated case law and later admitted using ChatGPT.
  • The court referred the contempt matter to Ontario’s attorney general; no amount was ordered.
  • Ontario Superior Court of Justice in Ontario, Canada.
  • Dec. 4 order; Justice Frederick Myers said it was a very unusual case.
Referred to the bar ChatGPT 2025-11-27
A barrister used ChatGPT to draft appeal grounds with a false citation and the tribunal reported him to the Bar Standards Board but did not start contempt proceedings.
MS v Secretary of State for the Home Department · Upper Tribunal (Immigration and Asylum Chamber)
barcouncil.org.uk ↗
The file →
  • MS v Secretary of State for the Home Department involved a barrister before the Upper Tribunal.
  • He included a false citation and later used ChatGPT to draft the grounds of appeal.
  • The tribunal referred him to the Bar Standards Board but did not initiate contempt proceedings.
  • Court: Upper Tribunal (Immigration and Asylum Chamber), Bangladesh; [2025] UKUT 305 (IAC).
  • Date: 2025-11-27; he did not use Westlaw or Lexis Nexis to check the work.
Referred to the bar ChatGPT 2025-11-17
CLP filed judicial-review grounds with bogus authorities and the Upper Tribunal said the author and COLP should expect referral.
R (Munir) v SSHD · City Law Practice Solicitors and Advocates · Upper Tribunal (IAC)
“It would be easy to think that this is a case about the naïve use of generative AI, but it is not merely about that; it is principally about supervision and the obligation to ensure that the tribunal is not misled.”
asadakhan.wordpress.com ↗
The file →
  • R (Munir) v SSHD involved City Law Practice Solicitors and Advocates and Zubair Rasheed.
  • Judicial-review grounds were filed with bogus authorities and incorrect citations.
  • The Upper Tribunal said the conduct should ordinarily be referred to a regulator.
  • Upper Tribunal (IAC), United Kingdom; Judges Lindsley, Keith and Blundell.
  • 17 November 2025; the court stressed supervision failures and mentioned ChatGPT.
Referred to the bar ChatGPT 2025-10-29
Adam Hyman filed an AI-generated divorce brief with fake cases and misquotes, and the Appellate Court of Maryland referred him to the Attorney Grievance Commission.
Adam Hyman divorce brief matter · Adam Hyman · Appellate Court of Maryland · MD
“it is unquestionably improper for an attorney to submit a brief with fake cases generated by AI.”
thedailyrecord.com ↗
The file →
  • Adam Hyman was the lawyer referred to the Attorney Grievance Commission.
  • He submitted a divorce brief prepared with ChatGPT that contained fake cases and misquotes.
  • The court imposed a referral to the AGC, with no dollar amount stated.
  • The incident was in the Appellate Court of Maryland in Maryland.
  • The opinion was issued Oct. 29, 2025; Judge Kathryn Graeff said attorneys must verify cited authority.
Referred to the bar ChatGPT 2025-10-06
A lawyer filed grounds of appeal with at least two non-existent authorities, and the judge ordered the solicitor to show cause why the matter should not be referred to the SRA.
AK v Secretary of State for the Home Department · Upper Tribunal
damiencharlotin.com ↗
The file →
  • AK v Secretary of State for the Home Department involved a lawyer's appeal grounds.
  • The false citations likely came from unchecked generative-AI drafting.
  • The judge directed the solicitor to show cause about an SRA referral.
  • Upper Tribunal, UK.
  • 6 October 2025; the page names ChatGPT as the AI tool.
Referred to the bar ChatGPT 2025-09-18
Barrister Muhammad Mujeebur Rahman cited a non-existent case generated with ChatGPT and was referred to the Bar Standards Board.
Y (China) · Muhammad Mujeebur Rahman · Upper Tribunal (Immigration and Asylum Chamber)
“We do however conclude that this is a case where referral to a regulator, in this instance the BSB, is most definitely appropriate”
localgovernmentlawyer.co.uk ↗
The file →
  • Muhammad Mujeebur Rahman was the barrister referred to the BSB.
  • He filed an immigration appeal relying on the bogus case Y (China) generated with ChatGPT.
  • The Upper Tribunal referred him to the Bar Standards Board; no contempt or police action was taken.
  • The court was the Upper Tribunal (Immigration and Asylum Chamber) in the UK.
  • On 2025-09-18, judges said he had not ensured the accuracy of what was placed before the tribunal.
Referred to the bar ChatGPT 2025-08-12
A barrister filed ChatGPT-drafted grounds with a fictitious Court of Appeal authority and was found to have attempted to mislead the tribunal and referred to the BSB.
MS (Bangladesh) · Upper Tribunal (Immigration and Asylum Chamber)
“attempted to mislead”
searchthe.law ↗
The file →
  • MS (professional conduct: AI generated documents) is the named matter.
  • ChatGPT-drafted grounds cited a fictitious Court of Appeal authority.
  • The barrister was referred to the Bar Standards Board.
  • The court was the Upper Tribunal (IAC).
  • Promulgated 12 August 2025; the barrister produced further unverified AI output after a short adjournment.
Referred to the bar $100K ChatGPT 2025-07-24
A federal judge sanctioned three Butler Snow LLP attorneys for filing motions written by generative AI that included false case citations.
Frankie Johnson v. Jefferson S. Dunn et al. · Butler Snow attorneys · United States District Court for the Northern District of Alabama · AL
“"failing to prevent AI hallucinations in legal filings"”
prnewswire.com ↗
The file →
  • Johnson v. Dunn; three Butler Snow LLP attorneys
  • Filed five fabricated citations in a case
  • Disqualified and referred to bar regulators in every state where they were licensed
  • U.S. District Court for the Northern District of Alabama
  • July 23, 2025; Judge Anna M. Manasco issued the order
Referred to the bar ChatGPT 2025-06-06
The claimant's solicitor relied on 45 client-provided case citations, 18 fictitious, and the court referred him to the SRA.
Hamad Al Haroun v Qatar National Bank [2025] EWHC 1383 (Admin) · Abid Hussain; Primus Solicitors · Divisional Court
“a matter of the utmost seriousness”
dacbeachcroft.com ↗
The file →
  • Hamad Al-Haroun v Qatar National Bank QPSC and QNB Capital LLC; Abid Hussain of Primus Solicitors
  • Witness statements contained eighteen non-existent case authorities and misquoted genuine ones
  • The court did not initiate contempt proceedings and said referral to the regulator was more appropriate
  • Divisional Court, UK; the article says the decision was published on 6 June 2025
  • Dias J called it "a matter of the utmost seriousness" and said counsel failed to check the information provided by the client
Referred to the bar ChatGPT 2025-03-31
The court found seven of nine cited authorities were non-existent, apparently AI-generated, refused leave to appeal, and referred the matter to the Legal Practice Council.
Mavundla v MEC: Department of Co-Operative Government and Traditional Affairs KwaZulu-Natal and Others [2025] ZAKZPHC 2 · Pietermaritzburg High Court · South Africa
“irresponsible and downright unprofessional”
iol.co.za ↗
The file →
  • Mavundla v MEC: Department of Co-Operative Government and Traditional Affairs KwaZulu-Natal and Others
  • Seven of nine authorities in the applicant’s submissions were found to be entirely non-existent, apparently generated by AI.
  • The court refused leave to appeal and referred the matter to the Legal Practice Council.
  • Pietermaritzburg High Court, South Africa.
  • Judge Bezuidenhout; the article says this was the clearest African example of AI hallucinations contaminating filings.
Referred to the bar ChatGPT 2025-01-31
A lawyer filed submissions with false citations and quotes generated by ChatGPT, and Judge Skaros referred the conduct to the regulatory body.
Valu v Minister for Immigration and Multicultural Affairs (No 2) · Federal Circuit and Family Court of Australia (Division 2)
“The conduct of the ALR, in filing an application and submissions which contained citations to Federal Court of Australia cases which do not exist and alleged quotes from the Tribunal’s decision which do not exist, falls short of the standard of competence and diligence that the applicant in the substantive proceedings was entitled to expect from his legal representative.”
lst.org.au ↗
The file →
  • Valu v Minister for Immigration and Multicultural Affairs (No 2) involved a lawyer referred to the regulatory body.
  • The filings contained false citations and quotes generated using ChatGPT.
  • Judge Skaros referred the lawyer's conduct for consideration.
  • Federal Circuit and Family Court of Australia (Division 2).
  • 2025-01-31; the conduct also involved correspondence with the Court without the consent of the other parties.
Referred to the bar ChatGPT 2025-01-01
A barrister cited a false case generated by ChatGPT and the Upper Tribunal referred the barrister to the BSB after the citation was not checked.
MS (Bangladesh) (Professional Conduct: AI Generated Documents) · Upper Tribunal
5essex.co.uk ↗
The file →
  • MS (Bangladesh) (Professional Conduct: AI Generated Documents) involved a barrister.
  • The barrister cited a false case generated by ChatGPT and failed to check its authenticity.
  • The Upper Tribunal referred the barrister to the BSB.
  • Upper Tribunal, location not stated on the page.
  • The article says the tribunal applied Ayinde guidance and the false citation came from ChatGPT.
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”
getvoibe.com ↗
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.
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