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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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199
Incidents tracked
40
Incidents in 2026
$11,578
In fines, where reported
3 of 199 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 75 of 199 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 32 Gemini 4 Claude 2 Perplexity AI 2 AI Overviews 1 ChatGPT-4o 1 ChatOn 1 Eve 1 Grammarly 1 MX2.law 1 OpenCase 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 199 incidents. Clear filters

Caught, not sanctioned
Counsel cited a nonexistent authority in an opening brief and delayed correcting it, but the court declined to impose sanctions.
Lichfield v. Kubler · U.S. Court of Appeals for the Tenth Circuit
holonlaw.com ↗
The file →
  • Lichfield v. Kubler involved an opening brief citing a fake authority.
  • Counsel cited one nonexistent case and misrepresented two real cases, correcting them late.
  • The court declined to impose sanctions, issuing a warning instead.
  • Decided by the Tenth Circuit (183 F.4th 1248).
  • The court held hallucinated citations must be corrected explicitly and without prompting.
Caught, not sanctioned
The court declined to add new sanctions against attorney Castro, noting previous AI citation issues had improved.
Leafwell, Inc. v. The Doc App, Inc. · Castro · M.D. Florida · FL
damiencharlotin.com ↗
The file →
  • Leafwell, Inc. v. The Doc App, Inc. involved attorney Castro failing to review AI-generated filings
  • Prior filings contained fabricated citations, but the attorney's citations had improved
  • The court declined to add new sanctions, keeping existing penalties from a prior order in place
  • The ruling was issued by the U.S. District Court for the Middle District of Florida
  • The decision was issued on 9 June 2026
Caught, not sanctioned
The Church of Scientology asked the California Supreme Court to review an appellate order that declined to sanction Boies Schiller Flexner LLP over AI citation errors.
Boies Schiller Flexner LLP · Boies Schiller Flexner LLP · California Supreme Court · CA
law360.com ↗
The file →
  • Boies Schiller Flexner LLP faced review requests over AI citation errors in a California lawsuit.
  • The Church of Scientology alleged the firm submitted a brief containing artificial intelligence-generated citation errors.
  • An appellate court declined to impose sanctions on the law firm.
  • The Church of Scientology petitioned the California Supreme Court to review the refusal to sanction.
  • The underlying matter involves a harassment and retaliation suit pending against the Church of Scientology.
Caught, not sanctioned
The court upheld an eviction order after finding a pro se appellant submitted AI-fabricated legal references and misquoted statutes in his appeal.
Samuel Robinson · Tennessee Court of Appeals · TN
“Simply put, artificial intelligence, partly due to its lack of 'real intelligence,' is not yet—and perhaps never will be—a reliable substitute for thorough legal research”
omegatechnologysolutionsgroupinc.com ↗
The file →
  • Pro se appellant Samuel Robinson challenged his eviction using AI-generated content
  • The submission contained fabricated decision details, incorrect dates, and fake quotes
  • The court imposed no monetary sanctions but upheld the lower court's eviction ruling
  • Tennessee Court of Appeals, state court in Tennessee
  • Decision issued by Judge Andy Bennett noting AI lacks real intelligence for legal research
Caught, not sanctioned
The court declined to issue sanctions for early AI-hallucinated filings but relieved the defendant of replying to future filings.
Thomas v. Del. Tech. & Cmty. Coll. · U.S. District Court for the District of Delaware · DE
fsbrlaw.com ↗
The file →
  • Thomas v. Del. Tech. & Cmty. Coll.
  • Pro se plaintiff filed over 49 motions containing AI-hallucinated cases and quotes
  • Court declined to award sanctions but relieved defendant of responding to future filings
  • U.S. District Court for the District of Delaware (Connolly, J.)
  • Rulings issued in late 2025
Caught, not sanctioned
Counsel filed a brief with fictitious case citations that the Tax Court said were likely generated by AI, but the opinion did not impose sanctions.
Clinco v. Commissioner · Clinco’s counsel · U.S. Tax Court
“Submitting a brief with fictitious caselaw is a recipe for sanctions.”

Cases that don't exist

  • Cacchillo v. Commissioner
  • Miller v. Commissioner
  • Tefel v. Commissioner
journalofaccountancy.com ↗
The file →
  • Clinco v. Commissioner involved counsel for the taxpayers.
  • The brief cited nonexistent cases in support of a notice-of-deficiency argument.
  • The Tax Court warned that fake citations can lead to sanctions, but imposed none here.
  • U.S. Tax Court; federal; judge Holmes’s opinion.
  • T.C. Memo. 2026-16; the court said the citations suggested something cooked up by AI.
Caught, not sanctioned
The court noted a pro per appellant's use of phony citations but ultimately did not impose sanctions.
Patterson v. Nuvision Credit Union · California Court of Appeal, Fourth District, Division Two · CA
“Attorneys who have filed briefs containing citations to fabricated legal authority have been sanctioned….Pro se litigants have been warned of the same possible outcome.”
metnews.com ↗
The file →
  • Patterson v. Nuvision Credit Union; pro per appellant Trina R. Patterson.
  • Appellant filed a brief containing citations to fabricated legal authority generated by AI.
  • No sanctions were imposed despite warning the pro se litigant.
  • California Court of Appeal, Fourth Appellate District, Division Two (State court).
  • Unpublished opinion authored by Justice Frank J. Menetrez on July 2.
Caught, not sanctioned 2026-08-25
The court declined to refer counsel to the disciplinary commission despite citation inaccuracies in a brief because there were no fake cases and counsel attempted to correct them.
Benjamin v. State · Appellate Court of Maryland · MD
“We again urge counsel, however, to use AI responsibly and check the accuracy of all citations before submitting a brief to this Court, or any other court.”
ediscoveryllc.com ↗
The file →
  • Counsel submitted a brief containing AI-related legal citation inaccuracies in Benjamin v. State.
  • The brief contained inaccurate references but no entirely fabricated cases.
  • The court declined to impose sanctions or refer counsel to the Attorney Grievance Commission.
  • Decided by the Appellate Court of Maryland in an unreported opinion.
  • Dated August 25, 2026; counsel sought to rectify errors prior to the state's filing.
Caught, not sanctioned Gemini
Michael Cohen provided fake cases from Google Bard to his attorney, which were filed, but the judge declined to sanction due to a lack of bad faith.
Cohen matter · Michael Cohen · U.S. District Court for the Southern District of New York · NY
layer3labs.io ↗
The file →
  • The Cohen matter involved Michael Cohen and his attorney.
  • Cohen gave his lawyer fake cases generated by Google Bard (now Gemini), which were subsequently filed in court.
  • Judge Jesse Furman declined to impose sanctions after finding no bad faith by Cohen.
  • The matter was handled in the U.S. District Court for the Southern District of New York.
  • The decision was issued in 2024 regarding citations created by Google Bard/Gemini.
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