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Courts on AI / Fabricated or misquoted citations

Booker v. The Kroger Co.

United States District Court for the Northern District of Georgia · Federal district courts · GA · · No. 1:26-cv-02006-SDG · order

The Northern District of Georgia sanctions plaintiff’s counsel in Booker v. Kroger after finding fake, false and misleading case authorities and an untruthful denial of AI use. The order imposes an $8,000 court fine and requires documentation of completed ethics and technology CLE.

Disposition
The court sanctioned plaintiff's counsel $8,000 and ordered proof of completed ethics and technology CLE training.
Recorded conduct
Plaintiff’s counsel filed four fake, false or misleading case authorities and falsely told the court he had not used AI tools. — outcome: fine; actor: lawyer; $8,000
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

This matter is before the Court on its previous Order to Show Cause [ECF 53] directed to counsel for Plaintiff to explain why he should not be sanctioned for using fake or hallucinated case authorities, as well as misrepresenting the content of real case authorities, in his filings with the Court. Because Plaintiff’s counsel, as an officer of the Court, deliberately lied to this Court about his artificial intelligence (AI) use and because Plaintiff’s counsel’s response to the Order to Show Cause [ECF 58] lacks credibility, is evasive, and seeks to divert accountability from his own misconduct, sanctions are warranted. ... The Court’s Order to Show Cause highlighted four purported cases cited by Plaintiff’s counsel that represented the most egregious examples of fake, false, and misleading case authorities. Counsel for Plaintiff is ordered to pay a fine of $1,000 for each of these fake, false, and misleading case authorities. In addition, this fine will be doubled as a result of Plaintiff’s counsel’s lies to this Court. Accordingly, Plaintiff’s counsel’s total fine for his repeated Rule 11 violations is $8,000, payable to the registry of the Court.

Authorities cited in the passage: Fed. R. Civ. P. 11

compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub