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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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8
Incidents tracked
1
Incidents in 2026
$77,039
In fines, where reported
1 of 8 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 4 of 8 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 151 Claude 9 CoCounsel 8 Copilot 8 Gemini 8 Lexis+ AI 6 AI-assisted legal software 4 Westlaw Precision 4 ChatGPT-4o 2 ChatOn 2 Eve 2 Google AI 2 LEAP 2 Perplexity AI 2 AI Overviews 1 Archie 1 Centient AI 1 ChatGPT-4 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 GPT-3.5 1 Ghostwriter Legal 1 Google Scholar 1 Grammarly 1 Grok 1 Irys 1 Legal Genius 1 LegalAI 1 MX2.law 1 OpenCase 1 Strongsuit 1 vLex Fastcase 1

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

Hall of Shame

All Caught, not sanctioned 4 Outcome unclear 1 Reprimanded 1 Referred to the bar 1 Fined 1

Showing 1–8 of 8 incidents involving Gemini. Clear filters

Referred to the bar Gemini 2026-09-03
The court struck Deutsche Bank's appellate brief containing four fake citations generated by AI and referred the matter to disciplinary counsel.
Douglas v. Deutsche Bank National Trust Co. · Loishirl W. Hall · District of Columbia Court of Appeals · DC
“The use of artificial intelligence must be accompanied by the application of actual intelligence in its execution.”

Cases that don't exist

  • Abadie v. District of Columbia
  • Cason v. National Consumer Cooperative Bank
  • Osborne v. District of Columbia

+1 more

i-dont-bluebook.ghost.io ↗
The file →
  • Douglas v. Deutsche Bank National Trust Co. involving attorney Loishirl W. Hall and firm McCabe, Weisberg & Conway
  • Attorney filed an appellate brief with four nonexistent case citations generated using an AI search tool
  • The court struck the appellee's brief and referred the matter to the Office of Disciplinary Counsel
  • D.C. Court of Appeals (Washington, D.C.)
  • Google AI search tool was used, and the court ruled that ignorance of generative AI risks is no longer credible
Caught, not sanctioned Gemini
Michael Cohen provided fake cases from Google Bard to his attorney, which were filed, but the judge declined to sanction due to a lack of bad faith.
Cohen matter · Michael Cohen · U.S. District Court for the Southern District of New York · NY
layer3labs.io ↗
The file →
  • The Cohen matter involved Michael Cohen and his attorney.
  • Cohen gave his lawyer fake cases generated by Google Bard (now Gemini), which were subsequently filed in court.
  • Judge Jesse Furman declined to impose sanctions after finding no bad faith by Cohen.
  • The matter was handled in the U.S. District Court for the Southern District of New York.
  • The decision was issued in 2024 regarding citations created by Google Bard/Gemini.
Caught, not sanctioned Gemini
An attorney cited an unrelated Supreme Court precedent and later said they had not properly reviewed it after searching with Google Gemini.
Ulsan District Court matter · an attorney at the Ulsan District Court · Ulsan District Court
koreaherald.com ↗
The file →
  • Ulsan District Court matter; an attorney at the Ulsan District Court
  • The attorney cited an unrelated Supreme Court precedent in a filing
  • The page reports no sanction, only the attorney's later acknowledgment
  • Ulsan District Court, South Korea
  • Published June 14, 2026; the attorney said the search was done using Google Gemini
Fined $77K Gemini 2025-12-18
MIO Legal Consultants LLP filed a defence with AI-fabricated and unsupported case citations, and the court ordered indemnity costs.
Arabyads Holding Limited v. Gulrez Alam Marghoob Alam [2025] ADGMCFI 0032 · MIO Legal Consultants LLP · Abu Dhabi Global Market Court of First Instance
““The fault for reliance on AI hallucinations as factually accurate lies not with the research programme,  but with the person responsible for conducting the search.””
theaskconsultancy.com ↗
The file →
  • Arabyads Holding Limited v. Gulrez Alam Marghoob Alam [2025] ADGMCFI 0032 involved MIO Legal Consultants LLP.
  • The firm filed a 327-paragraph defence containing cases that did not exist or did not support the propositions cited.
  • The court ordered AED 282,508 in indemnity costs, about USD 77,039.
  • The order was issued by the Abu Dhabi Global Market Court of First Instance in Abu Dhabi.
  • On 2025-12-18, Justice Paul Heath KC said the fault lay with the person responsible for the search, not the AI.
Caught, not sanctioned Gemini 2025-12-04
The court declined to transfer the case and noted that counsel had cited AI-generated authorities, but no sanction order is described on the page.
In re Bard IVC Filters Products Liability Litigation · N.D. Ga. · GA
copyrightalliance.org ↗
The file →
  • In re Bard IVC Filters Products Liability Litigation; counsel
  • The page says counsel cited AI-generated authorities in the case
  • No sanction order is described on the page
  • N.D. Ga. in federal court, Georgia
  • 2025-12-04; the page mentions Gemini among AI tools
Reprimanded Gemini 2025-11-12
A Dubai-based lawyer cited two non-existent QFC cases in submissions, and the QFC Court found him in contempt but imposed no penal sanction.
Jonathan David Sheppard v Jillion LLC · A Dubai-based lawyer · Qatar International Court (QFC Court)
“It was inconceivable for any lawyer not to verify the case law citations produced by an AI tool with the actual body of case law published by the QFC Court.”

Cases that don't exist

  • Al Khor International School v. Gulf Contracting Co. (QFC 2022)
  • Doha Bank v. KPMG (QFC App 2019)
qatarlaw.com ↗
The file →
  • Jonathan David Sheppard v Jillion LLC; a Dubai-based lawyer
  • He relied on AI research and cited two non-existent QFC cases
  • The court found contempt but imposed no penal sanction
  • Qatar International Court (QFC Court), Qatar
  • 2025-11-12; the court said lawyers must verify AI-produced citations
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