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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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Incidents tracked
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Incidents in 2026
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In fines, where reported
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The curve

Incidents per month

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

May 2025 Oct 2026

Blamed by name

ChatGPT 152 Claude 10 CoCounsel 8 Copilot 8 Gemini 8 Lexis+ AI 8 Westlaw Precision 5 AI-assisted legal software 4 ChatGPT-4o 2 ChatOn 2 Eve 2 Google AI 2 LEAP 2 Perplexity AI 2 vLex Fastcase 2 AI Overviews 1 Archie 1 Centient AI 1 ChatGPT-4 1 ClearBrief 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 Harvey 1 Irys 1 Legal Genius 1 LegalAI 1 MX2.law 1 OpenCase 1 Protégé 1 Strongsuit 1

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

Hall of Shame

All Referred to the bar 1

Showing 1–1 of 1 incident involving Protégé. Clear filters

Referred to the bar Protégé 2026-07-10
Attorney Tyrone A. Blackburn had his motion struck and was referred to the Grievance Committee for repeatedly using false, AI-generated quotations in case citations.
Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law · Tyrone A. Blackburn · U.S. District Court for the Southern District of New York · NY
chuckgallagher.com ↗
The file →
  • Cartagena v. Dixon involved attorney Tyrone A. Blackburn.
  • Blackburn used false quotes in case citations across at least 17 instances, defending them as paraphrase.
  • The court struck his motion and referred him to the Grievance Committee.
  • The case was heard in the U.S. District Court for the Southern District of New York.
  • The ruling was handed down on July 10, 2026, noting a pattern of fabricating quotations.
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