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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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6
Incidents tracked
5
Incidents in 2026
$15,500
In fines, where reported
3 of 6 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 5 of 6 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 Fined 4 Warned 1 Reprimanded 1

Showing 1–6 of 6 incidents involving Lexis+ AI. Clear filters

Fined $2K Lexis+ AI
Lindsay filed memoranda of law with fabricated citations and was sanctioned $2,500 after the court found she used AI-generated hallucinations.
Jimenez-Fogarty v. Fogarty · Tricia S. Lindsay · U.S. District Court for the Southern District of New York, Magistrate Judge Gabriel W. Gorenstein · NY
“"[C]ourts in this [C]ircuit have repeatedly found that presenting AI-generated hallucinations as valid caselaw constitutes subjective bad faith."”
holonlaw.com ↗
The file →
  • Jimenez-Fogarty v. Fogarty; Tricia S. Lindsay was sanctioned.
  • She filed two memoranda of law citing numerous nonexistent cases.
  • The court imposed a $2,500 fine and required notice to her client and other judges.
  • U.S. District Court for the Southern District of New York; Magistrate Judge Gabriel W. Gorenstein.
  • The opinion said Lindsay used an AI program and referenced Lexis Nexis AI-driven features.
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.”
ediscoveryllc.com ↗
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 $10K Lexis+ AI 2026-07-02
An AI-assisted brief filed in a civil appeal contained fabricated citations and inaccurate quotations, and the court imposed $10,500 in sanctions on the attorney and his firm.
Landberg v. City of New York · Michael Sanders; Law Offices of Michael S. Lamonsoff PLLC · Appellate Division of the New York State Supreme Court, Second Department · NY
“"It's striking, concerning, disappointing, and saddening to think that members of the bar would forward cases to a court that don't exist, and to think that the lawyers on the other side of that didn’t read it for whatever reason, didn’t check it."”
forchellilaw.com ↗
The file →
  • Michael Sanders and Law Offices of Michael S. Lamonsoff PLLC were sanctioned.
  • Sanders filed a brief containing fake citations and fake quotations from AI-assisted research.
  • The court imposed $10,500 total: $8,000 on Sanders and $2,500 on the firm.
  • Appellate Division of state Supreme Court, Second Department, New York.
  • June 26, 2026 article; Sanders said the citations came from hallucinated AI and he failed to verify them.
Fined $2K Lexis+ AI 2026-04-28
A lawyer was sanctioned $2,500 and ordered to report to other courts after submitting fabricated case law produced via LexisNexis+ (Protégé).
Tekoma Chaney v. Transdev Services Inc. et al. · C.D. California · CA
habeas.ai ↗
The file →
  • Tekoma Chaney v. Transdev Services Inc. et al. involved an unnamed lawyer.
  • The attorney submitted fabricated case law generated by an AI tool.
  • The court imposed a $2,500 monetary sanction and reporting to other courts.
  • The case was heard in the Central District of California.
  • Decided on April 28, 2026, using LexisNexis+ (Protégé).
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
Three nonexistent cases, including a Supreme Court decision, were cited in an employment discrimination appeal, leading to public admonishment.
Bolden v. Baltimore Gas & Electric Co (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 In re Nwaubani, an attorney was sanctioned.
  • Three nonexistent cases, including a fake Supreme Court decision, were cited in an appeal.
  • The sanction was a public admonishment for violating Fourth Circuit Local Rule 46(g)(1)(c).
  • The incident occurred in the U.S. Court of Appeals, 4th Cir.
  • On 2026-03-11, the attorney denied using generative AI, resulting in disciplinary action.
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