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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
3
Incidents in 2026
$15,500
In fines, where reported
3 of 4 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 3 of 4 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 53 Claude 4 Lexis+ AI 4 Westlaw Precision 4 CoCounsel 3 Copilot 2 AI-assisted legal software 1 Archie 1 ChatOn 1 ClearBrief 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 Gemini 1 Ghostwriter Legal 1 Google AI 1 Google Scholar 1 Grok 1 Irys 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 1–4 of 4 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.
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.
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