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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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251
Incidents tracked
81
Incidents in 2026
$1,813,310
In fines, where reported
186 of 251 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 139 of 251 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 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 251 Caught, not sanctioned 199 Warned 126 Referred to the bar 98 Reprimanded 85 Outcome unclear 53 Filing dismissed 36 Suspension 2 Upcoming sanction 1

Showing 1–10 of 251 incidents. Clear filters

Fined $15K
An Illinois appellate court imposed a $15,000 sanction on an attorney for citing hallucinated AI-generated case law in a legal brief.
In re Marriage of Edwards · Illinois Appellate Court, Second District · IL
jdsupra.com ↗
The file →
  • In re Marriage of Edwards involves an unnamed attorney sanctioned by the court.
  • The attorney cited hallucinated AI-generated case law in legal submissions.
  • The court imposed a monetary sanction of $15,000.
  • The ruling was issued by the Illinois Appellate Court, Second District.
  • Reported by Hicks Johnson on September 1, 2026, highlighting regulatory oversight.
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 $1K ChatOn
The plaintiff’s reply brief used ChatOn to create false case citations, and the court ordered the attorney to pay a $1,000 penalty.
Benjamin v. Costco Wholesale Corp. · U.S. District Court for the Eastern District of New York · NY
holonlaw.com ↗
The file →
  • Benjamin v. Costco Wholesale Corp.; the plaintiff’s attorney was penalized
  • The reply brief included numerous case citations created by ChatOn that were false
  • The court ordered a $1,000 penalty
  • U.S. District Court for the Eastern District of New York
  • Magistrate Judge Lee G. Dunst found mitigating factors, including remorse and voluntary CLE participation
Fined $3K ChatGPT
Walters filed papers with hallucinated citations; the court sanctioned him for the fake authorities.
Park v. Kim · Mark Walters · U.S. District Court, Southern District of New York · NY
“The opinion is short and direct.”

Cases that don't exist

  • Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014)
holonlaw.com ↗
The file →
  • Park v. Kim; Mark Walters was sanctioned
  • He filed briefs containing hallucinated legal citations
  • $3,000 monetary fine
  • U.S. District Court, Southern District of New York, New York
  • The page links the misconduct to ChatGPT-generated fake citations
Fined $60K
A law firm partner and the firm were sanctioned $59,500 combined after submitting roughly 14 fabricated or misrepresented citations in a lawsuit.
Mack v. Anderson · Goldberg Segalla · Cook County Circuit Court · IL

Cases that don't exist

  • Mack v. Anderson
yesh.world ↗
The file →
  • Lead-paint poisoning suit involving a Goldberg Segalla partner and the law firm
  • Submitted roughly 14 fabricated or misrepresented citations in court filings, including Mack v. Anderson
  • Monetary fine of $10,000 for the partner and $49,500 for the firm, totaling $59,500
  • Cook County court in Chicago, Illinois
  • Reported in December 2025 regarding fabricated legal citations submitted to the court
Fined $1K Irys 2026-09-15
Los Angeles County Judge Elizabeth L. Bradley sanctioned Jacquelene A. Robinson $999.99 for citing AI-generated nonexistent cases and fabricated quotes across five motions.
Fa’alagilagi Meni-Siliga v. A’s Contractor, Inc., et al. · Jacquelene A. Robinson · Cal. Super. Ct. L.A. County · CA
law360.com ↗
The file →
  • Meni-Siliga v. A's Contractor Inc. et al. involving Jacquelene A. Robinson of Musick Peeler & Garrett LLP.
  • Robinson filed five motions containing AI-generated fake cases, fabricated quotes, and false statements of law.
  • The court imposed a monetary fine of $999.99, which fell just below the $1,000 threshold for mandatory reporting to the state bar.
  • The incident occurred in Los Angeles County Superior Court, California.
  • The attorney used the AI tool Irys and subsequently attended an AI legal ethics class before submitting an apology.
Fined $5K ChatGPT 2026-09-11
Attorney Stephen D. Aarons was held in direct contempt and fined $5,000 after using ChatGPT to draft a murder appeal that contained fabricated witnesses and testimony.
Stephen Aarons · Stephen D. Aarons · New Mexico Supreme Court · NM
“So either you have buried your head in the sand ... and that’s an intentional choice to be uninformed, or you took a gamble, and neither of those are consistent with the code of conduct.”
yahoo.com ↗
The file →
  • Attorney Stephen D. Aarons was sanctioned by the court in connection with his representation of Oscar Renee Sandoval.
  • Aarons used ChatGPT to draft an appeal brief that fabricated four witnesses, invented testimony, and misrepresented legal authorities.
  • The court held Aarons in direct contempt, fined him $5,000, struck his briefs, barred him from appearing, and referred him to the Disciplinary Board.
  • The decision was handed down by the New Mexico Supreme Court in Santa Fe, New Mexico.
  • The sanction order was issued on September 9, 2026, after Aarons acknowledged relying on ChatGPT output without verifying it against the record.
Fined $3K 2026-09-09
A lawyer was ordered to complete two AI-ethics CLE courses and pay $3,000 in monetary sanctions after using AI tools that fabricated and misrepresented case law.
Beus Gilbert PLLC v. Brigham Young University et al. · Mr. Pehrson, Mr. Clark · U.S. District Court for the District of Utah · UT
casemine.com ↗
The file →
  • Beus Gilbert PLLC v. Brigham Young University et al.
  • A lawyer used ClearBrief, Claude, ChatGPT, and Gemini to generate filings containing fabricated and misrepresented case law.
  • The court ordered monetary sanctions of $3,000 and required two AI-ethics CLE courses.
  • U.S. District Court for the District of Utah
  • Decision issued September 9, 2026, involving multiple commercial and proprietary AI tools.
Fined $2K 2026-09-08
A lawyer was subjected to a $1,750 monetary sanction for submitting a filing with AI-fabricated case law.
State ex rel. Steven Schnell v. Honorable Rebecca Richardson · CA Missouri · MO
damiencharlotin.com ↗
The file →
  • State ex rel. Steven Schnell v. Honorable Rebecca Richardson
  • A lawyer submitted a filing containing a fabricated case citation from an unidentified AI tool.
  • The court imposed a monetary sanction of $1,750.
  • Missouri Court of Appeals
  • Order issued September 8, 2026.
Fined $10K
Attorney James Louis Policchio faced a $10,000 sanction recommendation after quoting three fake cases in court filings due to unverified AI use.
James Louis Policchio · James Louis Policchio · U.S. District Court for the Southern District of Indiana · IN
“Yet these situations represent an abdication of those personal and professional responsibilities to those very machines, which to date have not proven themselves”
inkfreenews.com ↗
The file →
  • Indianapolis attorney James Louis Policchio cited three hallucinated cases in a multi-defendant lawsuit.
  • Policchio relied on AI after canceling his subscription to legal research platform Lexis.
  • A judge recommended a $10,000 monetary sanction against Policchio for the fake citations.
  • The case was heard by Chief Judge James R. Sweeney II in the Southern District of Indiana.
  • Policchio cited an overwhelming workload and inability to afford cite-checking software as causes.
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