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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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86
Incidents tracked
30
Incidents in 2026
$86,945
In fines, where reported
5 of 86 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 49 of 86 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 13 CoCounsel 1 Eve 1 Gemini 1 Lexis+ AI 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 125 Referred to the bar 101 Reprimanded 86 Outcome unclear 56 Filing dismissed 37 Suspension 2 Upcoming sanction 1

Showing 1–10 of 86 incidents. Clear filters

Reprimanded
The court issued a formal Ermahnung after counsel submitted a plausible fake German citation combining a real journal page range with a non-existent file number.
17 WF 144/25 · KG Berlin

Cases that don't exist

  • BGH, Beschl. v. 14.11.2007 – XII ZB 183/07, FamRZ 2008, 137
llms-for-lawyers.com ↗
The file →
  • Matter 17 WF 144/25 was decided by the KG Berlin in 2025.
  • The brief contained a fabricated German citation assembling real journal pages with an invented file number.
  • The court conducted an extensive review ('aufwändige Prüfung') and issued a formal Ermahnung (reprimand).
  • The citation passed casual inspection because the page range contained a real maintenance decision.
  • The incident illustrated how generative AI constructs highly plausible hybrid citations.
Reprimanded
Attorney used generative AI to file motions with fake cases, misstatements, and a fictitious jury instruction, resulting in fee forfeiture and mandatory CLE.
Dastou v. Holmes · Middlesex Superior Court · MA
“By submitting motions and briefs that contain hallucinations and misstatements of the law, the lawyer violates their professional obligations.”
masslegalresources.com ↗
The file →
  • Dastou v. Holmes involved an attorney using generative AI for filings.
  • Filings contained fake cases, wrong quotes, misstated holdings, and a fictitious jury instruction.
  • Court barred attorney from billing client for tainted work and ordered mandatory CLE.
  • Middlesex Superior Court, Massachusetts, presided over by Judge Keren Goldenberg.
  • Date: June 2025; court ruled lawyers have a duty of competence and candor.
Reprimanded
Attorney was publicly reprimanded by the Board of Bar Overseers after staff used an AI program to generate unverified citations in court filings.
Matter of Marullo · Marullo · Board of Bar Overseers · MA
masslegalresources.com ↗
The file →
  • Matter of Marullo involved attorney Marullo disciplined for unverified AI research.
  • Staff used an AI program for motion research without attorney verification.
  • Board of Bar Overseers issued a public reprimand for ethical violations.
  • Massachusetts Board of Bar Overseers state disciplinary proceeding.
  • Date: 2025; attorney violated rules on competence, diligence, and supervision.
Reprimanded
A lawyer filed an appellate brief with eight DEA adjudications, seven misrepresented and one nonexistent, and the Third Circuit reprimanded him.
McCarthy v. United States Drug Enforcement Administration · U.S. Court of Appeals for the Third Circuit
“Attorney has harmed his credibility with this Court.”
holonlaw.com ↗
The file →
  • McCarthy v. United States Drug Enforcement Administration; the physician assistant’s lawyer was sanctioned.
  • He filed an opening brief using eight DEA adjudications from his client, but seven were misrepresented and one did not exist.
  • The Third Circuit reprimanded him in a precedential decision, with no monetary penalty imposed.
  • U.S. Court of Appeals for the Third Circuit; Judge Cindy Chung authored the decision.
  • The court said it would have imposed a monetary penalty absent the lack of prior Third Circuit guidance.
Reprimanded ChatGPT
An Oklahoma Supreme Court reprimanded an attorney for submitting legal motions containing AI-generated fake case citations.
Lawrence Wheeler · Lawrence Wheeler · Oklahoma Supreme Court · OK
“the careless use of generative artificial intelligence … damages the integrity and credibility of the legal system.”

Cases that don't exist

  • Cummings v. Cimarron Elevator Co.
  • Hawkins v. Linhart
oklahoman.com ↗
The file →
  • An unnamed attorney was reprimanded by the Oklahoma Supreme Court.
  • The attorney submitted legal motions containing AI-generated fabrications.
  • The sanction imposed was a formal public reprimand.
  • The matter was handled by the Oklahoma Supreme Court.
  • The reprimand occurred in May (year not specified); the court warned AI misuse damages legal integrity.
Reprimanded ChatGPT
The court reprimanded an attorney for filing a murder appeal brief containing hallucinated police testimony generated by ChatGPT.
State of New Mexico v. Manuel Sifuentes · L. Helen Bennett · New Mexico Supreme Court · NM
threads.com ↗
The file →
  • State v. Sifuentes involved defense attorney L. Helen Bennett.
  • Bennett used ChatGPT to draft a brief containing fabricated police testimony.
  • The New Mexico Supreme Court issued a formal public reprimand.
  • The ruling was handed down by the New Mexico Supreme Court.
  • The court noted ChatGPT invented testimony not in the actual trial record.
Reprimanded
A prosecutor was suspended from Supreme Court practice for six months after filing unverified AI-generated citations.
Payne v The State · Supreme Court of Georgia · GA
naturalandartificiallaw.com ↗
The file →
  • Payne v The State involved a prosecutor using AI to draft court filings without verification.
  • Filings contained at least 9 non-existent or unsupported citations plus additional AI-generated authorities.
  • The Supreme Court of Georgia suspended the prosecutor's privilege to practice before it for 6 months.
  • The incident was resolved in the Supreme Court of Georgia.
  • The court required 12 additional hours of legal education on ethics and AI use.
Reprimanded
A junior barrister was severely reprimanded for issuing documents filled with AI errors, including entirely fake cases.
Ayinde case
“There are serious implications for the administration of justice and public confidence in the justice system if artificial intelligence is misused.”
sg.news.yahoo.com ↗
The file →
  • The Ayinde case involved an unnamed junior barrister who was severely reprimanded.
  • The barrister submitted legal documents filled with AI errors and entirely fake cases.
  • The court issued a severe reprimand and a clear warning regarding AI misuse.
  • The incident occurred in a UK court jurisdiction.
  • The ruling took place in June of the previous year.
Reprimanded ChatGPT
Zachary Larsen was handed a stayed indefinite suspension, two years of supervised probation, and a public reprimand for submitting fake AI-generated citations to the court.
Zachary Larsen · Zachary Larsen · Minnesota Supreme Court · MN
webstat.net ↗
The file →
  • Attorney Zachary Larsen was disciplined by the Minnesota Supreme Court.
  • Larsen used ChatGPT to draft a motion that contained six hallucinated, fake case citations.
  • The court issued an stayed indefinite suspension, public reprimand, and 2 years of probation.
  • The decision was handed down by the Minnesota Supreme Court in Minnesota.
  • The court's ruling in December 2023 noted Larsen showed reckless disregard for the truth.
Reprimanded
A patent attorney was publicly reprimanded by the USPTO OED after submitting an AI-generated claim construction chart in federal court containing hallucinated citations to the intrinsic record.
In re Brian E. Mitchell · Brian E. Mitchell · United States Patent and Trademark Office · CA
ipwatchdog.com ↗
The file →
  • In re Brian E. Mitchell involved California patent attorney Brian E. Mitchell.
  • Mitchell used AI tools to draft and review a claim construction chart that included hallucinated citations to a patent's intrinsic record.
  • The USPTO Office of Enrollment and Discipline issued a public reprimand with no monetary fine.
  • The discipline was issued by the USPTO OED regarding filings submitted in the E.D. Pa.
  • This was the first USPTO disciplinary order predicated on AI-generated hallucinated citations to a patent's intrinsic record.
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