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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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4
Incidents tracked
4
Incidents in 2026
$2,500
In fines, where reported
1 of 4 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

Blamed by name

ChatGPT 156 Claude 9 Copilot 8 Gemini 7 Lexis+ AI 4 LegalAI 3 Westlaw Precision 3 ChatOn 2 CoCounsel 2 LEAP 2 AI-assisted legal software 1 AI-based legal software 1 Archie 1 Centient AI 1 ChatGPT-4o 1 Descrybe.ai 1 Eve 1 GPT-3.5 1 Generative artificial intelligence (unsp 1 Ghostwriter Legal 1 Google AI Overview 1 Google Scholar 1 Grammarly 1 Grok 1 Legal Genius 1 Lexis 1 Lexis Nexis 1 Morgan & Morgan’s in-house Artificial In 1 OpenCase 1 OpenLaw 1 Perplexity AI 1 Westlaw CoCounsel 1 Westlaw’s CoCounsel 1 in-house AI database 1

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

Hall of Shame

All Fined 2 Warned 1 Reprimanded 1

Showing 4 incidents involving Lexis+ AI. Clear filters

Warned Lexis+ AI 2026-08-07
Counsel filed briefs with fabricated quotations, said she used LexisNexis brief analysis for citation checking, and the court discharged the show-cause order but warned of future sanctions.
Smith v. Polk Co. · U.S. District Court for the Western District of North Carolina · NC
“The Court is deeply troubled by the errors previously identified in the Plaintiff’s filings, and counsel’s letter does little to allay the Court’s concerns.”
edrm.net ↗
The file →
  • Smith v. Polk Co. involved plaintiff's counsel and fabricated quotations in filings.
  • Counsel said she used LexisNexis brief analysis and denied AI research hallucinations.
  • The court discharged the show-cause order but warned similar future filings would be sanctioned.
  • U.S. District Court for the Western District of North Carolina, North Carolina.
  • Aug. 7, 2026; the court was troubled that counsel could not explain the origin of the fabricated quotations.
Fined Lexis+ AI 2026-04-06
The State Bar Court approved discipline after Khalifeh filed a federal trademark brief with nonexistent and irrelevant AI-assisted citations and failed to disclose generative AI use.
Omid Emile Khalifeh · Omid Emile Khalifeh · State Bar Court · CA
“Courts and clients must be able to trust that the filings attorneys submit are accurate, supported, and compliant with professional standards,”
latimes.com ↗
The file →
  • Omid Emile Khalifeh was accused by the State Bar of California.
  • He filed an April 2025 federal trademark brief with a nonexistent citation and two irrelevant AI-assisted citations.
  • The State Bar Court approved discipline, including probation and a 30-day suspension.
  • State Bar Court, California.
  • April 6, 2026; he said the brief was informed by Lexis+ AI.
Reprimanded Lexis+ AI 2026-03-11
Counsel submitted briefs with three nonexistent cases in an employment appeal; the Fourth Circuit publicly admonished him.
In re: Eric Chibueze Nwaubani · Eric Chibueze Nwaubani · Fourth Circuit Standing Panel on Attorney Discipline
“three nonexistent cases, each with materially different citations than those of the cases [the attorney] meant to cite”

Cases that don't exist

  • Nationwide Mutual Insurance Co. v. Jackson, 548 U.S. 629 (2006)
  • Commodity Futures Trading Commission v. Glencore Ltd., 611 F.3d 1330 (Fed. Cir. 2010)
  • In re Acres Properties, Inc., 100 F.3d 1307 (7th Cir. 1996)
nortonrosefulbright.com ↗
The file →
  • In re: Eric Chibueze Nwaubani; attorney Eric Chibueze Nwaubani
  • Briefs in Bolden v. Baltimore Gas and Electric Co. cited three nonexistent cases
  • The Fourth Circuit publicly admonished him
  • Fourth Circuit Standing Panel on Attorney Discipline; federal; location not specified on the page
  • No date given on the page; the panel said D.C. Rule 8.4(d) applied regardless of whether Gen AI was used
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