Tracker

Sanctions watch

Every incident where a lawyer got caught filing AI-fabricated citations. The Hall of Shame.

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Incidents tracked

Incidents in 2026

$10,000

In fines, where reported

1 of 2 report an amount

The curve

Incidents per month

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

Apr 2025 Jan 2026 Sep 2026

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 Outcome unclear 1 Fined 1

Showing 1–2 of 2 incidents involving Google AI. Clear filters

Fined $10K Google AI 2026-03-18

The Oregon Court of Appeals fined William L. Ghiorso $10,000 after his appellate brief cited 15 hallucinated cases.

Doiban v. Oregon Liquor and Cannabis Commission · William Ghiorso · Oregon Court of Appeals · OR

“submitting a brief with unchecked and ultimately fabricated citations may breach an attorney’s duties of professionalism, truthfulness, and candor to the court.”

kgw.com ↗

The file →

Doiban v. Oregon Liquor and Cannabis Commission involving petitioner's counsel
Counsel submitted an opening brief containing 15 fabricated case citations and 9 non-existent quotes from unverified AI/search output
Court imposed a $10,000 monetary sanction and ordered a replacement brief with certified non-AI verification
Oregon Court of Appeals
Decided March 18, 2026; counsel admitted using unverified search results and AI for outlining

Outcome unclear Google AI 2025-12-18

Counsel relied on AI-generated Google summaries and linked databases for authority in an opposition brief.

Zhang v. NPR · U.S. District Court for the District of Columbia · DC

midwestfrontier.ai ↗

The file →

Zhang v. NPR involved counsel relying on AI-generated search summaries.
Attorney used Google search summaries linking to sources like VLex, unaware they were AI-generated.
The court issued an order to show cause regarding the submission.
U.S. District Court for the District of Columbia under Judge Howell.
Decided December 18, 2025, illustrating AI search summary hallucination risks.

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