legaltech.fyi Beta

Tracker

Sanctions watch

Every incident where a lawyer got caught filing AI-fabricated citations. The Hall of Shame.

Embed this
53
Incidents tracked
19
Incidents in 2026
$5,237
In fines, where reported
1 of 53 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 26 of 53 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 6 CoCounsel 1 Gemini 1 Google 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 126 Referred to the bar 98 Reprimanded 85 Outcome unclear 53 Filing dismissed 36 Suspension 2 Upcoming sanction 1

Showing 1–10 of 53 incidents. Clear filters

Outcome unclear
An attorney for State Farm apologized to LA Superior Court Judge Elizabeth Bradley after submitting motions in limine containing fabricated cases.
State Farm Insurance Company litigation · Los Angeles County Superior Court · CA
dailyjournal.com ↗
The file →
  • State Farm litigation involving home fire coverage in Carson
  • An attorney submitted motions in limine rife with fabricated cases
  • The attorney apologized to the court for the AI misuse
  • Los Angeles County Superior Court under Judge Elizabeth Bradley
  • The matter involved motions in limine submitted for an October trial
Outcome unclear
Judge Loren L. Alikhan ordered attorney Don Quinn to explain three inaccurate brief citations and disclose if generative AI was used.
Garner v. Transit Employees Federal Credit Union · Don Quinn · U.S. District Court for the District of Columbia · DC
alabnews.com ↗
The file →
  • Attorney Don Quinn of Quinn Patton was ordered by the court to explain inaccurate citations in a job bias case.
  • A brief was filed containing at least three citations with language or findings not present in the actual court opinions.
  • No formal sanction was imposed yet; the court issued an order to show cause asking if generative AI was used.
  • The case took place in the US District Court for the District of Columbia before Judge Loren L. Alikhan.
  • The order required an explanation within 14 days following a Bloomberg Law report published in September 2026.
Outcome unclear
Pleadings contained AI-generated hallucinations and fabricated authorities, leading the court to reference its generative AI guidance.
VTB Bank PJSC v Kuanyshev & Others · DIFC Court
lawgratis.com ↗
The file →
  • VTB Bank PJSC v Kuanyshev & Others
  • Pleadings contained AI-generated arguments with numerous fabricated or incorrectly described authorities
  • Court identified hallucinations and cited existing guidance on generative AI usage
  • DIFC Court (DIFC CFI 121/2025)
  • Highlighted that plausible-looking legal reasoning from AI is not necessarily reliable
Outcome unclear
Relator's counsel Jenna Rohr Conley admitted to citing two fictitious non-existent cases that misled the court.
ED114731 · Jenna Rohr Conley · Missouri Court of Appeals Eastern District · MO
“Relator's counsel, Jenna Rohr Conley, cited two cases that she now admits do not exist. These fictitious citations misled this Court”
websitedc.s3.amazonaws.com ↗
The file →
  • Case ED114731 involving relator's counsel Jenna Rohr Conley.
  • Counsel cited two fictitious non-existent cases in filings.
  • Sanction type and amount not specified in the text.
  • Missouri Court of Appeals, Eastern District.
  • Counsel admitted the citations do not exist and misled the court.
Outcome unclear
The court set aside a Rs-425.28 crore customs penalty after finding reliance on non-existent cases and AI-hallucinated propositions.
Vijay Ghanshyam Gadiya v. Union of India & Anr. · Supreme Court of India
deccanherald.com ↗
The file →
  • Vijay Ghanshyam Gadiya v. Union of India & Anr.
  • Submissions relied on non-existent cases and AI-hallucinated propositions.
  • The Supreme Court set aside a Rs-425.28 crore penalty as a result.
  • The incident took place before the Supreme Court of India.
  • The decision reaffirmed that attorneys cannot rely on fabricated AI precedents.
Outcome unclear ChatGPT
Two lawyers submitted non-existent judicial opinions with fake citations created by ChatGPT and continued defending them when questioned, resulting in sanctions.
Levidow, Levidow & Oberman P.C. · Levidow, Levidow & Oberman P.C · U.S. District Court for the Southern District of New York · NY
“the law firm of Levidow, Levidow & Oberman P.C. … abandoned their responsibilities when they submitted non-existent judicial opinions with fake quotes and citations created by the artificial intelligence tool ChatGPT”
dailycaller.com ↗
The file →
  • Levidow, Levidow & Oberman P.C. lawyers were sanctioned by a New York federal judge.
  • The attorneys submitted non-existent court cases and citations generated by ChatGPT.
  • The court imposed sanctions after the firm continued defending the fake cases.
  • The case took place in New York federal court.
  • A June 2023 order noted the firm abandoned its responsibilities by using ChatGPT fabrications.
Outcome unclear CoCounsel
A party relied on hallucinated research generated by the specialist legal AI tool CoCounsel.
U.S. v. Farris · U.S. Court of Appeals for the Sixth Circuit
midwestfrontier.ai ↗
The file →
  • U.S. v. Farris involved hallucinations from a specialized legal AI tool.
  • The court addressed hallucinated citations originating from CoCounsel.
  • Sanction type and amount are not specified in the text.
  • U.S. Court of Appeals for the Sixth Circuit.
  • Highlighted that even specialized legal tools like CoCounsel can hallucinate.
Outcome unclear ChatGPT
A lawyer was ordered to notify their client after using ChatGPT to generate three fabricated case citations and one misrepresented case.
Richard Paul Smith v. Verra Mobility Corporation et al. · M.D. Florida · FL
damiencharlotin.com ↗
The file →
  • Richard Paul Smith v. Verra Mobility Corporation et al. involved a lawyer.
  • The lawyer used ChatGPT, resulting in fabricated and misrepresented cases.
  • The court ordered the attorney to notify their client.
  • Decided in the U.S. District Court for the Middle District of Florida.
  • Issued on May 1, 2026, following an Order to Show Cause.
Outcome unclear $5K
A court issued a $5,237 adverse costs order against a lawyer who submitted fabricated and misrepresented case law.
Ascent Management, Inc. et al v. Shell Oil Company et al · Montgomery CC, Ohio · OH
damiencharlotin.com ↗
The file →
  • Ascent Management, Inc. et al v. Shell Oil Company et al involved a lawyer.
  • The attorney submitted fabricated and misrepresented case law citations.
  • The court imposed an adverse costs order of $5,237.
  • Decided in Montgomery County Common Pleas Court, Ohio.
  • The ruling was issued on April 30, 2026.
Get Sanctions Watch in your inbox
New AI-citation sanctions, the morning after they hit the docket.