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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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98
Incidents tracked
30
Incidents in 2026
$386,941
In fines, where reported
14 of 98 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 57 of 98 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 17 Claude 2 CoCounsel 2 LEAP 2 AI-assisted legal software 1 ChatGPT-4 1 Copilot 1 GPT-3.5 1 Gemini 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 98 incidents. Clear filters

Referred to the bar $10K
A solicitor and two barristers were referred to disciplinary regulators after AI-produced submissions and authorities contained fake and inaccurate citations.
Mertz & Mertz (No 3) [2025] FedCFamC1A 222 · Full Court of the Federal Circuit and Family Court of Australia
“the “extent and in what way it was used remains opaque, notwithstanding the written submissions of the solicitor responsible.””
aubreybrown.com.au ↗
The file →
  • Mertz & Mertz (No 3) [2025] FedCFamC1A 222 involved a solicitor and two barristers.
  • AI was used to prepare a Summary of Argument and List of Authorities with non-existent and inaccurate citations.
  • The court referred them to regulators and ordered $10,000 in costs against the solicitor.
  • Full Court of the Federal Circuit and Family Court of Australia; federal jurisdiction; location not stated.
  • The article says this was the first time an appellate court in Australia sanctioned practitioners for AI misuse.
Referred to the bar
A solicitor advocate filed AI-generated submissions containing false case citations and gave incorrect information to the court, resulting in a regulatory referral.
Tesar & Szep (No 3) [2026] FedCFamC1F 21 · Federal Circuit and Family Court of Australia
aubreybrown.com.au ↗
The file →
  • In Tesar & Szep (No 3), a solicitor advocate submitted AI-fabricated citations.
  • The solicitor provided false information about how the submissions were prepared.
  • The court referred the solicitor advocate to the Legal Services Commissioner.
  • Federal Circuit and Family Court of Australia handled the matter.
  • The solicitor was ordered to pay personal legal costs and barred from charging the client for that work.
Referred to the bar Gemini 2026-09-03
The court struck Deutsche Bank's appellate brief containing four fake citations generated by AI and referred the matter to disciplinary counsel.
Douglas v. Deutsche Bank National Trust Co. · Loishirl W. Hall · District of Columbia Court of Appeals · DC
“The use of artificial intelligence must be accompanied by the application of actual intelligence in its execution.”

Cases that don't exist

  • Abadie v. District of Columbia
  • Cason v. National Consumer Cooperative Bank
  • Osborne v. District of Columbia

+1 more

i-dont-bluebook.ghost.io ↗
The file →
  • Douglas v. Deutsche Bank National Trust Co. involving attorney Loishirl W. Hall and firm McCabe, Weisberg & Conway
  • Attorney filed an appellate brief with four nonexistent case citations generated using an AI search tool
  • The court struck the appellee's brief and referred the matter to the Office of Disciplinary Counsel
  • D.C. Court of Appeals (Washington, D.C.)
  • Google AI search tool was used, and the court ruled that ignorance of generative AI risks is no longer credible
Referred to the bar
Lawyers used AI and other sources to file witness statements with fictitious authorities, and the High Court accepted their self-referral without contempt.
Al-Haroun · High Court in England and Wales
“freely available generative artificial intelligence tools, trained on a large language model such as ChatGPT are not capable of conducting reliable legal research”
vu.co.uk ↗
The file →
  • Al-Haroun; the lawyers used AI tools in court papers.
  • Some cited authorities were fictitious, including one attributed to the judge.
  • The High Court supported their self-referral to the regulator, with no contempt finding.
  • High Court in England and Wales.
  • The page says they used publicly available AI tools, legal search engines and online sources.
Referred to the bar
The NLRB referred attorney Cynthia Sauter to an agency investigator for discipline after she submitted a filing containing fake legal citations.
Cynthia Sauter · Cynthia Sauter · National Labor Relations Board
“Sauter also cites to Board decisions that do not stand for the propositions for which they are cited and, most egregiously, to two purported Board decisions that do not exist at all,”
news.bloomberglaw.com ↗
The file →
  • Cynthia Sauter of Burdzinski & Partners Inc. was referred for discipline.
  • She submitted a filing containing nonexistent legal citations and transcript references.
  • The NLRB referred her to an agency investigator for possible discipline.
  • The decision was issued by the National Labor Relations Board.
  • The ruling noted Sauter cited two purported Board decisions that do not exist at all.
Referred to the bar 2026-08-27
The court denied Rule 11 sanctions on procedural grounds but recommended referring signing attorneys to a disciplinary committee for filing fabricated AI exhibits.
Thomas Raynard James v. Detective Kevin Conley, et al. · U.S. District Court for the Southern District of Florida · FL
damiencharlotin.com ↗
The file →
  • Thomas Raynard James v. Detective Kevin Conley, et al. involved plaintiff's counsel submitting unverified AI hallucinations.
  • Counsel included unverified IACP Training Keys in the Fifth Amended Complaint generated by AI.
  • Rule 11 sanctions were denied on procedural grounds, but the signing attorneys were referred for disciplinary review.
  • The decision was issued by the U.S. District Court for the Southern District of Florida.
  • The ruling was entered on August 27, 2026, finding counsel's reliance on unverified AI irresponsible.
Referred to the bar
A Florida state appeals court sanctioned an attorney and referred him to the state bar after finding his filings contained at least 46 AI hallucinations.
Florida Attorney AI Misuse Matter · Florida District Court of Appeal · FL
law360.com ↗
The file →
  • A Florida state appellate court sanctioned an unnamed Florida attorney.
  • The attorney's court filings contained at least 46 AI-generated hallucinations.
  • The court issued a monetary fine and referred the attorney to the state bar.
  • The matter occurred in a Florida state court of appeal.
  • The decision was issued on Friday in August 2026 due to the attorney's unapologetic AI use.
Referred to the bar 2026-08-12
An attorney was referred to the state bar after filing a certiorari petition containing fake AI-generated citations and claiming he accidentally submitted the wrong draft.
JMORR Properties, LLC v. Artist Alley Townhomes, LLC · Barry M. Leff · District Court of Appeal of the State of Florida, Fourth District · FL
“Counsel’s explanation that he mistakenly submitted the wrong draft of the petition does not excuse the failure to verify the accuracy of all citations in his filing.”
ediscoveryllc.com ↗
The file →
  • Barry M. Leff represented petitioner JMOR Properties, LLC in Florida state appellate court.
  • Leff submitted an AI-drafted certiorari petition containing false citations and non-existent case authority.
  • The court imposed a non-monetary sanction referring Leff to the Florida Bar for disciplinary proceedings.
  • The decision was issued by Florida's Fourth District Court of Appeal.
  • On August 12, 2026, the court held that inadvertently filing an unverified draft does not excuse the failure to verify citations.
Referred to the bar $10K
A California state appellate panel sanctioned a Pacific Palisades lawyer and reported him to the bar for AI-generated fake quotes in his opening and reply briefs.
In re Pacific Palisades lawyer · Pacific Palisades lawyer · California Second District Court of Appeal · CA
“In an apparent first, a California state appellate panel has sanctioned a Pacific Palisades lawyer and reported him to the bar for submitting AI-generated fabrications in his opening and reply briefs.”
law.com ↗
The file →
  • Pacific Palisades lawyer sanctioned in the Second District Court of Appeal.
  • He submitted AI-generated fabrications in his opening and reply briefs.
  • The court imposed a $10,000 sanction and reported him to the bar.
  • California Second District Court of Appeal, California.
  • Article dated Sept. 15, 2025; the page says this was an apparent first.
Referred to the bar AI-assisted legal software
Mr Dayal filed a list and summary of authorities containing entirely fabricated AI-generated case citations, and the regulator imposed practice restrictions.
Dayal · Mr Dayal · Federal Circuit and Family Court of Australia
qlsproctor.com.au ↗
The file →
  • Dayal; Mr Dayal, a Victorian solicitor,
  • He submitted a list and summary of authorities with entirely fabricated case citations generated by AI-based legal software.
  • The Victorian Legal Services Board imposed comprehensive practice restrictions and supervised practice requirements.
  • Federal Circuit and Family Court of Australia; Victoria.
  • The page says this was the first Australian case in which referral to a regulator had been concluded.
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