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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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21
Incidents tracked
6
Incidents in 2026
$1,000
In fines, where reported
1 of 21 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 6 of 21 incidents — the rest are undated or fall outside this window.

Blamed by name

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

Showing 21 incidents involving ChatGPT. Clear filters

Warned ChatGPT
A barrister misled the Tribunal by citing a fictitious Court of Appeal judgment generated by ChatGPT.
Upper Tribunal (Immigration and Asylum Chamber) · Upper Tribunal (Immigration and Asylum Chamber)
ein.org.uk ↗
The file →
  • Upper Tribunal (Immigration and Asylum Chamber) involved a barrister
  • The barrister cited a fictitious Court of Appeal judgment generated by ChatGPT
  • The Tribunal issued guidance and a stern warning
  • Upper Tribunal (Immigration and Asylum Chamber), England and Wales
  • Date not given; the page says this happened after ChatGPT-generated citations misled the Tribunal
Warned ChatGPT
Owoc filed a court motion with 11 AI-hallucinated citations and was sanctioned by the court.
Jack Owoc matter · Jack Owoc · California court · CA
futurism.com ↗
The file →
  • Jack Owoc was sanctioned in a California case.
  • He filed a motion with 11 AI-hallucinated citations to nonexistent cases.
  • The court ordered 10 hours of community service and future AI disclosure.
  • California court; state jurisdiction; location not further specified on the page.
  • The article says he admitted using generative AI and the sanction was for hallucinated citations.
Warned ChatGPT
An immigration barrister cited entirely fictitious or irrelevant cases in appeal grounds and the Upper Tribunal judge said he had likely used generative AI and tried to hide it.
Chowdhury Rahman · Chowdhury Rahman · Upper Tribunal
“The most obvious explanation is … that the grounds of appeal were drafted in whole or in part by generative artificial intelligence such as ChatGPT.”
theguardian.com ↗
The file →
  • Chowdhury Rahman was the immigration barrister in the Upper Tribunal case.
  • He cited cases that were described as entirely fictitious or wholly irrelevant.
  • The judge said Rahman likely used generative AI and considered reporting him to the Bar Standards Board.
  • Court: Upper Tribunal in the UK; the ruling was published on Tuesday.
  • Judge Mark Blundell ruled in September and said the submissions wasted the tribunal’s time.
Warned ChatGPT
A U.S. lawyer used ChatGPT to draft filings and cited fake cases; a federal judge responded with a standing order on AI use.
ChatGPT references nonexistent legal cases · A U.S. lawyer · federal judge
evidentlyai.com ↗
The file →
  • A U.S. lawyer in the ChatGPT case
  • He used ChatGPT and ended up citing entirely fake legal cases
  • The judge issued a standing order, not a monetary penalty
  • Federal court; the page gives no judge name or location
  • The page says the lawyer did not realize ChatGPT was a generative language tool
Warned ChatGPT
Three lawyers were warned after using ChatGPT to cite fake or incorrect legal cases in court, and two were ordered to take an AI training course.
Dutch lawyers warned for misusing ChatGPT in court · Three lawyers in the Netherlands
nltimes.nl ↗
The file →
  • Three lawyers in the Netherlands were warned
  • They misused ChatGPT to cite fake or incorrect legal cases in court
  • Sanction was a warning, and two lawyers had to take an AI training course
  • No court or judge name is given in the page text
  • The report says two were ordered to take an AI training course
Warned ChatGPT
A firm filed two briefs with five false ChatGPT-generated citations, and a federal judge was considering sanctions and potential fines.
another firm · federal judge
courtroomsciences.com ↗
The file →
  • Another firm faced possible sanctions for false citations.
  • Attorneys filed two briefs containing five ChatGPT-generated false citations.
  • The judge was considering sanctions and potential fines; no amount is given.
  • A federal judge in federal court.
  • The partner admitted using ChatGPT without verification and the firm apologized.
Warned ChatGPT
A lawyer’s suspected AI use led to fake cases being cited before the tribunal, and the tribunal warned that uploading confidential client documents to ChatGPT breached privilege.
Munir v. Secretary of State for the Home Department · Immigration and Asylum Chamber
blakes.com ↗
The file →
  • Munir v. Secretary of State for the Home Department involved a lawyer suspected of using AI-generated fake cases.
  • The lawyer said he did not know how the fake cases appeared in his submissions.
  • The tribunal warned that uploading confidential client documents into an open-source AI tool breaches client confidentiality and waives privilege.
  • Immigration and Asylum Chamber (U.K.).
  • The page says the lawyer admitted putting client letters and other confidential material in ChatGPT.
Warned ChatGPT
Two lawyers filed a brief with non-existent cases; the High Court warned of severe sanctions after ChatGPT was found to have been used.
High Court of Justice in London warning matter · High Court of Justice in London
“The technology was “not capable of conducting reliable legal research.””
posteo.de ↗
The file →
  • Two lawyers submitted a brief citing cases that could not be found.
  • One lawyer had asked ChatGPT for evidence supporting the claim.
  • The High Court warned of severe sanctions, not a monetary penalty.
  • High Court of Justice in London.
  • Last summer; judge said the tools can produce plausible but incorrect responses.
Warned ChatGPT
A regulated immigration adviser filed an appeal application using fictitious case law from Google’s AI Mode and faced potential SRA censure.
UK v Secretary of State for the Home Department · Mr. Zubair Rasheed of City Law Practice Solicitors · Upper Tribunal (Immigration and Asylum Chamber)
“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.”
thelens.slaughterandmay.com ↗
The file →
  • UK v Secretary of State for the Home Department involved a regulated immigration adviser.
  • He used fictitious case law from Google’s AI Mode in an application for permission to appeal.
  • The court said it would have reported him if he had not self-reported.
  • Court: Upper Tribunal (Immigration and Asylum Chamber), UK.
  • The adviser also put draft emails and Home Office letters into ChatGPT.
Warned ChatGPT 2026-05-05
Kelly Guagenty filed a brief with AI-caused citation errors, mischaracterizations and an improper quotation; Judge Stacey D. Neumann ordered AI training and new safeguards but no fine.
Jessica Fuller v Hyde School · Karen Guagenty · U.S. District Court for the District of Maine · ME
“Although AI can be a useful aid in research and drafting, its use does not diminish an attorney's nondelegable duties of diligence, candor, and reasonable inquiry.”
habeas.ai ↗
The file →
  • FULLER v. HYDE SCHOOL involved Attorney Kelly Guagenty.
  • She submitted two filings with AI-generated erroneous legal citations.
  • The court imposed non-monetary sanctions.
  • United States District Court for the District of Maine, Maine.
  • May 5, 2026; counsel said the AI used was either Claude or ChatGPT.
Warned $1K ChatGPT 2026-03-20
Corwin St. Raymond was not fined, but Judge Carl Barbier issued him a formal warning over the AI-tainted filing in his department.
Gentry v. City of New Orleans · Corwin St. Raymond · U.S. District Court for the Eastern District of Louisiana · LA
wdsu.com ↗
The file →
  • Gentry v. City of New Orleans also involved Chief Deputy City Attorney Corwin St. Raymond.
  • The motion contained nine made-up case citations generated by AI.
  • Judge Carl Barbier issued a formal warning, not a fine.
  • The case was in the U.S. District Court for the Eastern District of Louisiana.
  • On March 20, 2026, the court warned him about improper AI use in his department.
Warned ChatGPT 2026-03-01
Several authorities and citations in judicial review grounds could not be located; the Tribunal found the errors consistent with AI-hallucination risk and accepted a supervising solicitor's explanation.
R(Munir) and SOSHD · Upper Tribunal Immigration and Asylum Chamber
““Freely available generative artificial intelligence tools, trained on a large language model such as ChatGPT are not capable of conducting reliable legal research.”
naturalandartificiallaw.com ↗
The file →
  • R(Munir) and SOSHD concerned false authorities and citations in judicial review grounds.
  • The Tribunal found the pattern of errors consistent with AI-hallucination risk.
  • The supervising solicitor accepted that false citations generated by AI may have been used.
  • Upper Tribunal Immigration and Asylum Chamber, UK.
  • 2026-03-01; the Tribunal stressed supervision and accurate checking of documents.
Warned ChatGPT 2026-02-22
Three lawyers received a warning and two had to take a mandatory course after citing non-existent judgments generated by ChatGPT in court filings.
First disciplinary measures for lawyers · Judges in Arnhem, Rotterdam, and Groningen
verileges.nl ↗
The file →
  • Three lawyers were disciplined.
  • They cited non-existent judgments generated by ChatGPT.
  • The sanctions were a warning and mandatory course, with no amount stated.
  • Judges in Arnhem, Rotterdam, and Groningen.
  • 22 February 2026; the page says this was the first disciplinary measure.
Warned ChatGPT 2026-02-06
Kenosha County DA Xavier Solis filed a brief with undisclosed AI use and false legal citations; Judge David Hughes struck the filing and sanctioned him.
Xavier Solis brief incident · 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.”
wjiinc.org ↗
The file →
  • Kenosha County DA Xavier Solis was sanctioned
  • He filed a response with undisclosed AI use and false legal citations
  • Judge David Hughes struck the filing and sanctioned him; no dollar amount was stated
  • Kenosha County Circuit Court in Wisconsin
  • Feb. 6 hearing; the article says the AI system was described as such as ChatGPT
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
Warned ChatGPT 2025-01-10
Counsel submitted an expert declaration drafted with LLM help that cited two nonexistent articles and misattributed a third; the court excluded the testimony.
Kohls v. Ellison · Jeff Hancock · United States District Court for the District of Minnesota · MN
“Rule 11 imposes a “personal, nondelegable responsibility” to ensure the accuracy of everything filed.”
counselpro.ai ↗
The file →
  • Kohls v. Ellison; Minnesota Attorney General Ellison’s counsel
  • An expert declaration used LLM help and contained two nonexistent articles and one misattribution
  • The court excluded the expert testimony; no monetary sanction stated
  • U.S. District Court for the District of Minnesota, Minnesota
  • Jan. 10, 2025; the court stressed Rule 11’s personal, nondelegable responsibility
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
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
Warned ChatGPT 2023-05-27
A lawyer submitted a filing with six non-existent cases invented by ChatGPT, and the judge called it absurd and considered sanctions.
A lawyer submitted a filing with six non-existent cases invented by ChatGPT · New York judge · NY
“The judge called it absurd and considered sanctions.”
verileges.nl ↗
The file →
  • A lawyer filed a New York submission with fabricated cases.
  • ChatGPT invented six non-existent cases in the filing.
  • The judge considered sanctions but the page does not say they were imposed.
  • New York.
  • 27 May 2023; the judge called it absurd.
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