Competence, fees and billing

2026-08-27 · United States District Court for the Southern District of Florida

The Southern District of Florida recommends denying Miami-Dade County’s Rule 11 motion against James on safe-harbor grounds but says counsel relied for months on unverified AI-generated IACP Training Keys. The recommendation calls the Keys AI hallucinations and recommends referral of four signing attorneys.

In his Response, Plaintiff concedes that the Keys in the Fifth Amended Complaint that are the subject of the Motion were based on unverified AI-generated research, and although Plaintiff does not state so explicitly, the Keys were AI hallucinations. See id. at 6-7. As explained below, the Court finds Plaintiff’s counsel’s use of and repeated …

2026-08-20 · United States District Court for the District of Delaware · provisional

The District of Delaware addresses plaintiff’s counsel’s disclosure that StrongSuit generated erroneous claim-construction briefing. The court notes counsel’s candor, withdrawn sections, and defense burden, declines Rule 11 sanctions, and warns that future AI mistakes in the case may result in sanctions.

After Plaintiff’s counsel disclosed to the Court that the previously filed Joint Claim Construction Brief (“Joint Brief”) (D.I. 105) featured multiple errors due to his use of generative artificial intelligence (“AI”), the Court ordered counsel to show cause in writing as to why the Court should not impose sanctions for counsel’s conduct pursuant to Federal …

2026-08-20 · United States District Court for the Northern District of California

The Northern District of California grants in part a renewed fee motion and discharges a sanctions order. The order records that plaintiff’s counsel reimbursed SJ 6070 $14,500 for expenses incurred addressing nonexistent cases cited in opposition to an earlier attorneys’ fees motion.

The Court also ordered Plaintiff’s counsel to show cause why he should not be sanctioned in an amount sufficient to reimburse Defendant for expenses it incurred in addressing nonexistent cases cited by Plaintiff in opposition to the first attorneys’ fees motion. See Order to Show Cause, ECF 30. The parties have resolved that issue informally, …

2026-08-18 · Court of Appeals of Washington, Division Two · provisional

The Washington Court of Appeals affirms a parenting plan and awards Rebekah Muriel fees for responding to Jonathan Farris’s response brief. The court says the brief twice cited nonexistent Marriage of Sanjuan, surmises AI-assisted drafting, deems the filing frivolous, and sets the fee amount for the commissioner.

However, we award appellate attorney fees to Rebekah under RAP 18.9(a) for her time spent reviewing and responding to Jonathan’s response brief. Here, Jonathan’s brief twice cites to Marriage of Sanjuan to support his arguments, but as Rebekah points out in her reply brief, no such case exists. We surmise that Jonathan used artificial intelligence …

2026-08-14 · Superior Court of Vermont, Windham Unit · 2026 WL 2479362 · provisional

The Vermont Superior Court grants Brattleboro’s sanctions motion against Jeffrey Rivard and imposes a civil-division prefiling injunction. The order cites Rivard’s prior non-existent authorities, mismatched Vermont Reports citations, spurious record quotations, and repeated warnings that had not changed his filing conduct.

Plaintiff has himself been admonished by the Court for citing non-existent authority. In his brief, plaintiff cited several purported decisions of this Court, including “Slayton v. Willing, 2010 VT 56, ¶ 14, 188 Vt. 216, 4 A.3d 1155,” “Sorrell v. Wigginton, 154 Vt. 301, 303 (1990),” “Morrison v. City of Montpelier, 2011 VT 9, ¶ …

2026-08-14 · Court of Appeals of Indiana · provisional

The Court of Appeals of Indiana affirms the denial of David Brankle’s motion to compel and a $1,546 expenses award. The memorandum quotes the trial court’s finding that Brankle cited nonexistent rules and fictitious cases suggesting ChatGPT use, and holds hallucinated authorities cannot substantially justify the motion.

Brankle’s motion is totally without merit. First, Commercial Court Rules are inapplicable to this case[,] and Brankle should not cite to them again. Brankle’s repeated citations to rules that do not exist or fictitious cases leads the Court to opine that Brankle is using ChatGPT or other form of artificial intelligence to prepare his numerous …

2026-08-12 · District Court of Appeal of Florida, Fourth District

The Florida Fourth District Court of Appeal refers Barry Leff to the Florida Bar after a certiorari petition cited false AI-draft authority. Counsel says he filed the wrong draft; the court finds the petition misrepresented jurisdictional law, lacked controlling adverse authority, and cited non-existent authority.

Counsel filed a certiorari petition in this case that is riddled with false citations and arguments, including an unsupported allegation that this Court has “repeatedly entertained, and granted, certiorari review of orders vacating clerk’s defaults.” The petition cited a non-existent case allegedly from this Court and cited other cases that do not support this proposition. …

2026-08-12 · United States District Court for the Northern District of Alabama · 2026 WL 2350902 · provisional

The Northern District of Alabama sanctions Scott Morro for false citations, quotations, and legal representations in Chapman v. City of Priceville. The court treats client-drafted filings submitted without verification like unchecked AI work, publicly reprimands Morro, orders notice in pending cases, and directs publication.

The court finds, based upon its own careful review and Morro's admission, (doc. 34 at 1–2), that the purported citations, quotations, and representations of law in the filings at issue were fabricated. Accordingly, by citing nonexistent cases and attributing nonexistent quotations and propositions of law to actual authorities, Morro made false statements of law. Morro …

2026-08-11 · Appellate Court of Maryland · 2026 WL 2321382

The Appellate Court of Maryland affirms judgment for 72 Barrow St. Realty and taxes costs to Simon Eyong. The per curiam opinion notes earlier orders striking large portions of his self-represented briefs for fictitious legal citations and inaccurate summaries, and leaves a sanctions motion for remand.

72 Barrow has moved for sanctions against Mr. Eyong under Rules 1-341 and 8-504, arguing that his citation to fictional legal authority in his opening brief and his reply brief; the lack of legal authority for his positions; and his failure to prepare a record extract justify an award of reasonable attorneys’ fees and costs. …

2026-08-11 · United States District Court for the Western District of Arkansas

The Western District of Arkansas sanctions Nicholas Nesbitt in a consumer-credit case by imposing filing restrictions. The court says he relied on AI for legal research and writing, filed at least two motions with fabricated cases, apologized after a Rule 11 show-cause order, and continued filing improper papers.

Since then, Plaintiff has filed numerous replies without leave of Court, repetitive notices and motions, and at least two motions relying on fabricated cases. ... On July 17, 2026, the undersigned ordered Plaintiff to show cause why he should not be sanctioned under Federal Rule of Civil Procedure 11(b) for citing nonexistent case law in …

2026-08-10 · Court of Chancery of the State of Delaware

The Delaware Court of Chancery master recommends removing Gregory Palumbo as trustee, denying his accounting petition, and shifting fees. The report says the self-represented disbarred attorney cited Kuroda and Koninklijke for propositions they do not support, treated fictitious quotations as an AI hallmark, and found subjective bad faith.

Moreover, many of the cases cited by Respondent in support of his proposition neither expressly state nor even suggest the statements for which he invokes them. Respondent cites Kuroda v. SPJS Holdings, LLC for the proposition that (1) the proper procedural retort to a confusing claim is a Rule 12(e) motion for a more definite …

2026-08-10 · Arizona Court of Appeals, Division One · provisional

The Arizona Court of Appeals dismisses Stefanie Kuerschner’s appeal and awards appellate fees and costs. The court says her brief lacked record citations, repeatedly misquoted or misstated cases, included one unlocatable case, and repeated citation problems despite earlier warnings about AI-related errors.

Stefanie’s opening brief does not include a single citation to the record. Her opening brief also consistently misquotes cases and cites cases for propositions either not mentioned or directly contradicted by the case. And one case she cites appears not to exist. ... On page 27, the brief quotes State ex rel. Dep’t of Econ. …

2026-08-07 · United States District Court for the Western District of North Carolina

The Western District of North Carolina resolves summary-judgment and spoliation motions and discharges an AI show-cause order. The court says plaintiff’s counsel accepted responsibility for fabricated quotations but did not explain their origin or substantiate claims about an unnamed AI program.

On June 3, 2026, the Court directed counsel for the Plaintiff to show cause in writing as to why she should not be sanctioned for failure to comply with the Court’s Standing Order Regarding the Use of Artificial Intelligence. [Doc. 98 at 15]. The Court specifically directed counsel for the Plaintiff to explain both the …

2026-08-06 · United States District Court for the Middle District of Tennessee

The Middle District of Tennessee sanctions attorney Louis W. Ringger III after a filing contained hallucinated quotations and misleading citations. The order says unchecked AI-generated content contributed to the deficiencies, publicly reprimands Ringger, and orders him to pay $1,500 to the clerk.

On July 30, 2026, the Court ordered several of plaintiff's attorneys to show cause why they should not be sanctioned-under either or both of Rule 11 of the Federal Rules of Civil Procedure and the Court's inherent authority-for filing a document at Doc. No. 293 that contained hallucinated quotations and misleading citations. ... Ringger has …

2026-08-06 · United States District Court for the Northern District of Ohio

The Northern District of Ohio rules on Greater Cleveland Regional Transit Authority’s motion to dismiss and flags a Shimola citation. The court says the cited reporter page points to another case, Shimola does not support the proposition, and future hallucinated citations may be sanctioned.

The Court first addresses GCTRA’s reliance on Shimola. First, “State ex rel. Shimola v. City of Cleveland” is not found at “70 Ohio St.3d 40” as cited by GCRTA. That citation is to State ex rel. Hopkins v. Indus. Comm’n of Ohio, 70 Ohio St.3d 36, 635 N.E.2d 1257 (Ohio 1994). And that case was …

2026-08-06 · United States District Court for the District of Nebraska · 2026 WL 2267773 · provisional

The District of Nebraska grants an EAJA fee request and cautions plaintiff’s counsel over a cited Peterson decision. The order says the Eighth Circuit citation does not exist, a similarly named case lacks the quoted language, and Nebraska’s AI rule requires verification.

Plaintiff cites one case in her initial brief in support of the Motion for Attorney Fees. Filing No. 27-1 at 2. Plaintiff quotes Peterson v. U.S. Retirement Board, 785 F.2d 245 (8th Cir. 1986) as follows: Agency action found to be arbitrary and capricious or unsupported by substantial evidence is virtually certain not to have …

2026-08-05 · United States District Court for the Western District of Texas

The Western District of Texas issues a show-cause order in Cain v. Hyatt. The order says plaintiffs cited nonexistent Henry v. Kroger authority in a dismissal response and requires attorney Daniel Miguel Hernandez to appear under Rule 11(c)(3).

Plaintiffs cited nonexistent case Henry v. Kroger Co., No. 4:19-cv-00630, 2019 WL 6311295 (E.D. Tex. Nov. 25, 2019), in their Response to Defendant’s Motion for Partial Dismissal. Dkt. 9 at 7. Under Rule 11(b), an attorney certifies that legal citations in papers presented to the Court are correct “to the best of the person’s knowledge, …

2026-08-05 · Texas Court of Appeals, Fourth District · provisional

The Texas Fourth Court of Appeals reverses denial of SAISD’s jurisdiction plea and renders dismissal. Before reaching the merits, the court identifies four hallucinated opinions in Becerra’s brief and cautions counsel that similar future issues will not be tolerated.

We begin by noting that Becerra’s appellee’s brief cites eight judicial opinions, four of which appear to be hallucinations created by generative artificial intelligence: “Alief Independent School District v. Lozano, 543 S.W.3d 118 (Tex. App.—Houston [14th Dist.] 2018, pet. denied),” cited on page 23 of Becerra’s brief, does not exist. The citation 543 S.W.3d 118 …

2026-08-04 · United States District Court for the Southern District of Texas

The Southern District of Texas magistrate judge recommends summary judgment for SWBC Mortgage and Cenlar. The recommendation says plaintiffs’ counsel cited fabricated Pointe West and Tractebel cases, misused other authorities, and is reminded of Rule 11 duties.

Plaintiffs cite Pointe West Center, LLC v. It’s Alive, Inc., 796 S.W.2d 830, 838–39 (Tex. App.—Houston [1st Dist.] 1990, writ denied), and Motten v. Chase Home Financial, 821 F. Supp. 2d 988, 1008 (S.D. Tex. 2011), for the proposition that a cause of action for wrongful initiation of foreclosure proceedings exists. Pointe West is a …

2026-08-04 · United States District Court for the District of Connecticut

The District of Connecticut sanctions defense counsel Hilary Miller in a trademark dispute. The order says Miller used Open Law, Claude, and ChatGPT, submitted unverified AI-generated legal authorities with nonexistent quotations and erroneous citations, and must pay $3,500 with a grievance referral.

This Order addresses the Court’s previously issued Order to Show Cause concerning defense counsel Hilary Miller’s use of unverified generative artificial intelligence (“AI”) in this matter. Having considered counsel’s written response to the Order to Show Cause and his representations made at the show-cause hearing, the Court concludes that sanctions are warranted and imposes the …

2026-08-03 · United States District Court for the Eastern District of North Carolina · 2026 WL 2439988 · provisional

The Eastern District of North Carolina recommends dismissal of Damon Forney’s employment case as untimely and sanctions attorney Lucas Colantonio. The order says Colantonio repeatedly submitted fabricated authority after a warning, must pay Cary’s response fees, and is referred to the North Carolina State Bar.

The record provides clear and convincing evidence that Colantonio engaged in conduct that justifies imposing sanctions under the court's inherent authority. First, Colantonio provided erroneous case citations repeatedly even after being warned. Colantonio has admitted that the citation was erroneous. ... Thus the record establishes by clear and convincing evidence that Colantonio knowingly submitted a …

2026-07-31 · United States Bankruptcy Court for the Eastern District of Virginia · 2026 WL 2220314 · provisional

The Eastern District of Virginia bankruptcy court dismisses Alicia Mahar’s adversary complaint for lack of jurisdiction. Footnotes note that counsel cited a nonexistent In re Coastal Carolina Fruit Company decision and supplied incorrect court, Westlaw, or date information for three other mortgage cases.

At the March 26, 2026 hearing, the Court advised Ms. Mahar's counsel that one of the cases he cited in support of this proposition does not exist. ECF No. 61, Transcript of Mar. 26, 2026 hearing, at 9-10. Despite extensive efforts, the Court was unable to locate any case by the alleged name, and its …

2026-07-31 · Texas Court of Appeals, Twelfth District · provisional

The Texas Twelfth Court of Appeals affirms Kevin Higgins’s conviction. The opinion recounts defense counsel’s admission that an AI-produced evidentiary memorandum misstated case holdings because counsel did not read the cited cases, but holds Higgins did not establish Strickland prejudice.

Outside the jury’s presence, the trial judge referred to a written memorandum defense counsel filed regarding the admissibility of said items. During the ensuing colloquy between the trial judge and defense counsel, the trial judge stated that defense counsel’s memorandum misstated the holdings of several cases, whereupon defense counsel admitted that the memorandum was produced …

2026-07-31 · United States District Court for the District of Oregon

The District of Oregon partially suppresses statements in a criminal case. In resolving the Miranda arguments, the court notes that defense briefing supplied a quotation that does not appear in Smith and admonishes counsel, while recording counsel’s statement that the mistake was not caused by generative AI.

Perhaps recognizing that Smith does not support his argument, Williams resorts to providing a non-existent quotation from the case: “The Ninth Circuit held that officers cannot ‘prevent a suspect from making an unambiguous request for counsel by cutting him off.’ ” Reply, ECF 172 at 9. This Court admonishes Williams's counsel for misquoting Smith, but …

2026-07-30 · United States District Court for the District of Utah

The District of Utah grants transfer to Arizona and flags possible improper AI use in plaintiff’s opposition. The order says counsel cited two cases the court could not locate on Westlaw, quotes authority condemning fake opinions, and leaves the matter to the receiving judge.

Before addressing the substance of Defendants’ Motion, the Court calls attention to certain concerns it has regarding the Opposition Plaintiff’s counsel filed on March 10, 2026. In reviewing the Opposition, the Court located a number of case citations suggesting that the improper use of artificial intelligence may have occurred here. For example, the Opposition cites …

2026-07-30 · Texas Court of Appeals, Fourteenth District · provisional

The Fourteenth Court of Appeals affirms a child-custody modification judgment and sanctions Father’s lawyer. The court finds fabricated quotations from Harrison and Swim, unsupported assertions from Lenz and A.S., assumes AI hallucination rather than deliberate deception, and orders three additional hours of AI-focused CLE.

Finally, some discussion of appellant’s brief is warranted. As previously mentioned, appellant’s brief is disjointed and difficult to follow. However, that is not the only shortcoming of appellant’s briefing. It is obvious that appellant’s brief was either (1) the result of using artificial intelligence yielding hallucination citations or (2) a deliberate attempt to mislead this …

2026-07-30 · Texas Court of Appeals, Second District · provisional

The Texas Second Court of Appeals affirms a child-custody modification judgment on rehearing. The opinion notes Mother’s original brief cited a nonexistent case and that her counsel-filed amended brief cited nonexistent case portions and false quotations, but the court resolves the appeal on briefing and merits grounds.

Despite the lengthy preparation time, her opening brief’s purported legal analysis—which advanced six appellate issues—spanned just five pages with zero record references and a citation to a nonexistent case. Cf. Tex. R. App. P. 38.1(i). ... Three months later, on the day Father’s brief was due, Mother moved for leave to file an overhauled amended …

2026-07-29 · United States District Court for the District of Colorado

The District of Colorado magistrate judge recommends summary judgment and grants discovery-fee sanctions in part. The order separately finds Maloit’s briefs contain misquotations, misstatements, and seven nonexistent cases likely from generative AI, then orders her to show cause about additional sanctions.

Finally, it has come to the Court’s attention that Plaintiff’s Response briefs in opposition to the instant Motion for Summary Judgment [#91] and Motion for Sanctions [#87] contain defective citations to case law. These defects include (1) misattributed or inaccurately quoted language from cases, (2) misrepresentations of legal concepts associated with the cited cases, and, …

2026-07-28 · United States District Court for the Northern District of Texas

The Northern District of Texas denies disqualification motions in a commercial dispute. The opinion notes briefing problems, including one nonexistent Northern District citation likely caused by imprudent generative-AI reliance, and admonishes pro hac vice counsel about responsible AI use and Rule 11 obligations.

The filings in this case are riddled with inaccurate citations, seemingly deliberate misrepresentations of guiding caselaw and the factual record, failures to comply with Court rules, and, in at least one instance, advocacy using caselaw that does not exist, likely the result of imprudent reliance on a generative artificial intelligence tool. ... (See Int. Resp. …

2026-07-28 · Appellate Court of Illinois, First District · 2026 IL App (1st) 251462

The Illinois First District affirms dismissal of Kimberly Scott’s discrimination charge and sanctions attorney Mason Cole. The opinion says ChatGPT produced 10 false citations or quotations, fines Cole $15,000 at $1,500 per misstatement, and directs the clerk to send the opinion to the ARDC.

We also sanction petitioner’s attorney Mason Cole for submitting briefs containing false citations and quotations that are the product of artificial intelligence (AI) hallucinations. ... Petitioner’s briefs also contain false case citations. One such case, “Harris v. Illinois Human Rights Comm’n, 2022 IL App (1st) 210454,” does not exist at all. The citation 2022 IL …

2026-07-28 · United States District Court for the District of Arizona

The District of Arizona expands an AI show-cause inquiry against Elizabeth Tate. The order recounts Tate’s Claude AI workflow, finds that list-based cite checking missed false quotations in several filings, criticizes delegating whole-brief drafting to Claude, and requires a supplemental memorandum.

On July 8, 2026, the Court issued an order to show cause (“OSC”) requiring Plaintiff's counsel, Elizabeth Tate, to show cause why she should not be sanctioned or disciplined for including, in Plaintiff's response to Defendant's motion for attorneys’ fees, two false quotations from Ninth Circuit cases. ... Ms. Tate utilized Claude AI to help …

2026-07-24 · United States District Court for the Western District of Washington · provisional

The Western District of Washington sanctions Jocelyn Stewart in the LeDoux litigation. The order finds Stewart used ChatGPT and Claude without verifying outputs, causing dozens of false citations across briefs and expert reports, and imposes a $3,000 personal sanction plus future citation certifications.

In November and December 2025, Plaintiff Joann LeDoux submitted multiple filings containing dozens of inaccurate factual and legal citations which appeared “hallucinated” by a generative artificial intelligence tool. On February 4, 2026, the Court ordered Plaintiff’s counsel, Ms. Jocelyn Stewart, to show cause and explain why she should not be sanctioned for these errors. ... …

2026-07-10 · United States Court of Appeals for the Eleventh Circuit

The Eleventh Circuit affirms summary judgment for the Florida Department of Corrections and grants sanctions relief against Parnell’s counsel. The court strikes defective reply-brief material, awards fees for the sanctions motion, and refers counsel after finding two non-existent opinions and at least five non-existent quotations.

The FDOC has moved for sanctions under Federal Rule of Appellate Procedure 27 and our inherent authority, seeking attorney’s fees and to strike portions of Parnell’s reply brief. The FDOC argues that Parnell’s reply brief cites two non-existent court opinions and at least five non-existent quotations from our opinions. Parnell responds that he withdraws any …

2026-07-10 · United States Court of Appeals for the Eleventh Circuit

The Eleventh Circuit affirms dismissal of claims against Atlas Air and Flight Services International while referring plaintiffs’ counsel Anthony F. Sabatini for discipline. The court says his opening and proposed reply briefs contained repeated hallucinated case citations and that unverified AI-generated briefing violated duties to clients and the court.

Though the filings in this case were substandard in a variety of ways, we have saved the worst for last. The plaintiffs’ counsel Anthony F. Sabatini’s filings are riddled with citations to nonexistent, “hallucinated” cases. His opening brief relies on at least eight such cases, including one purportedly decided by this Court. After the defendants …

2026-07-07 · United States District Court for the Western District of Kentucky

On 2026-05-28, in Roger Patel et al. v. Chandresh Patel et al, the Western District of Kentucky warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. Counsel filed a response using quotations that did not appear in the cited source and authorities used for propositions they did not support.

RESPONDENTS MEMORANDUM OPINION AND ORDER In reviewing Petitioners’ Response to Respondents’ Motion to Dismiss (DN 61), the Court identified a series of citations and quotations that appear to be generative artificial intelligence (“AI”) hallucinations. Petitioners’ counsel—Daniel N. Thomas and Mary E. Jocelyn—were ordered to show cause why they should not be sanctioned pursuant to Fed. …

2026-07-01 · Court of Chancery of the State of Delaware

The Delaware Court of Chancery orders Richard P. Rollo and Richards, Layton & Finger to show cause over GenAI errors in an answering brief. The court says counsel did not verify citations, left fabricated legal synthesis in a corrected filing, and must address Rule 11 and firm-supervision issues.

GenAI offers a powerful tool to streamline legal practice and assist in advocacy. Using GenAI in preparing court filings is “not inherently problematic”—provided the attorney (or litigant) carefully verifies the accuracy of the output. Here, counsel acknowledges that the GenAI output was not verified before the Answering Brief was filed. The submission of hallucinated legal …

2026-06-23 · Supreme Court of the State of New York, Appellate Division, Second Department · 2026 NY Slip Op 03935

The New York Appellate Division, Second Department sanctions attorney Michael Sanders and Law Offices of Michael S. Lamonsoff, PLLC after an appellate brief used GenAI-assisted research. The court finds nonexistent cases, fictitious Court of Appeals quotations and misstatements, ordering $8,000 and $2,500 sanctions.

In this case, we impose sanctions upon an attorney and a law firm for submitting a brief, prepared with the assistance of generative artificial intelligence (hereinafter GenAI), containing citations to nonexistent cases, fictitious purported Court of Appeals quotations wholly contrary to actual law, and misrepresentations about what certain real cases actually held or decided. As …

2026-06-22 · Court of Appeals of Indiana

The Indiana Court of Appeals affirms multiple orders in Hoagland Family Limited Partnership’s sewer-system dispute with Clear Lake. While rejecting one appellate argument, the court says a Fox v. Fox citation and quotation did not exist, likely came from generative AI, and reminds counsel of candor duties.

This case appears to not exist. The reporter citation provided—“521 N.E.2d 1240”—leads to People v. Pira, 521 N.E.2d 1236 (Ill. App. Ct. 1988) (beginning on page 1236, ending on page 1243). The pincite provided—“521 N.E.2d [at] 1244”—leads to Hauk v. Day, 521 N.E.2d 1243 (Ill. App. Ct. 1988) (beginning on page 1243, ending on page …

2026-06-17 · Michigan Court of Appeals

The Michigan Court of Appeals affirms denial of Joyce Barber’s new-trial motion but sanctions her counsel for AI-related citation failures. The court holds that repeated fabricated and unsupported authorities violated Michigan court rules, remands to determine defendant’s actual damages and expenses, and refers counsel for possible investigation.

Counsel’s explanation does not excuse the violation. Artificial intelligence may be a useful tool for legal research and drafting, but the use of such technology does not alter an attorney’s professional obligations. Lawyers remain responsible for the filings they sign and submit. They must verify that cited authorities exist, read the authorities on which they …

2026-06-16 · Court of Appeals of Indiana

The Indiana Court of Appeals affirms a custody order in Holstein v. Holstein and denies Mother’s request for $5,000 in sanctions. The court says Father’s counsel included citations from his client without verification, corrected them promptly, and receives a warning rather than a monetary sanction.

These circumstances present an opportunity for this court to reemphasize the importance of verifying every citation, holding, and quote a litigant selects for inclusion in his or her filings to a court. We expect this even more so from an attorney when case-related information is provided by his non-lawyer client for use in his brief. …

2026-06-11 · United States District Court for the Eastern District of Texas · 2026 WL 1746259 · provisional

On 2026-06-11, in McCormick v. Texakoma Financial, the Eastern District of Texas publicly reprimanded plaintiff's counsel, imposed $6,000 in sanctions, ordered firmwide citation review, and required AI-focused CLE. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

This case presents yet another example of false legal citations caused by reliance on generative artificial intelligence (“AI”). ... the Court will issue sanctions against Plaintiff’s counsel, Amy L.B. Ginsburg.

2026-06-11 · California Court of Appeal, First Appellate District, Division Two

On 2026-06-11, in Quinteros v. Harbor Distributing, LLC, the California First District Court of Appeal imposed $6,000 in sanctions payable to the court and referred counsel to the California State Bar. Counsel filed opposition papers using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

This appeal arises out of an order issuing sanctions against Lipeles Law Group, APC and its attorneys ... for their evident misuse of generative artificial intelligence (AI) in an otherwise meritless pleading

2026-06-10 · United States Bankruptcy Court for the Northern District of Indiana · 2026 WL 1815400 · provisional

On 2026-06-10, in In re Garcia-Martz, the Northern District of Indiana Bankruptcy Court ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a brief using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

Figure 3 below cites the 13 deficient arguments previously mentioned above; captures additional questionable arguments, misleading quotes, a non-existent Bankruptcy Rule; internally inconsistent and contradictory arguments; and describes other problems with the Trustee's Brief. The Court would not have a problem if the issues below were isolated, or if only a few of them appeared. …

2026-06-09 · United States District Court for the Southern District of New York · provisional

On 2026-06-09, in LiveVideo.AI Corp. v. Redstone, the Southern District of New York awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee. Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

Constants also admitted that “he did not prepare, review, or file at least one of plaintiffs motions,” and nearly all of the motions in this matter contain the hallmarks of artificial intelligence (“Al”) fabrication, including non-existent hallucinated cases, formatting unchanged from that produced by Al platforms, and remnants of prompts that the drafter declined LEGAL …

2026-06-09 · United States District Court for the Middle District of Florida · provisional

On 2026-06-09, in Leafwell, Inc. v. The Doc App, Inc, the Middle District of Florida declined to add new sanctions but warned counsel that the order could support future professional-discipline proceedings. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

The remaining issue is not Castro’s use of artificial intelligence (“AI”) but his indolence in failing to review AI’s output.

2026-06-09 · United States District Court for the District of Colorado

On 2026-06-09, in Tlingit Haida Tribal Business Corporation v. OnePromom, the District of Colorado ordered plaintiff to show cause why the filing was not sanctionable and whether counsel complied with professional obligations. Counsel filed a motion using quotations that did not appear in the cited source.

The undersigned counsel certifies that generative artificial intelligence—specifically, Eve Legal—was used to draft this filing. ... the quoted language to Seale is nevertheless a misrepresentation to the Court—and a troubling one

2026-06-08 · 250th Judicial District Court of Travis County, Texas · provisional

On 2026-06-08, in Erica Whitesock v. Bird Global, Inc., and The City of Austin, the Travis County district court granted the City of Austin's jurisdictional plea, dismissed those claims with prejudice, and awarded $10,000 in attorney fees. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, authorities used for propositions.

✳ ✳ ✳ As counsel for the City of Austin has noted, Plaintiffs’ response to the City’s plea to the jurisdiction contains a non-existent quotation of a legal authority. The response falsely quotes the Texas Tort Claims Act as containing an exception to governmental immunity for “engaging in a proprietary function, including . . . …

2026-06-08 · United States District Court for the Western District of Tennessee

On 2026-06-08, in Bailey v. Sedgwick Claims Management Services, Inc, the Western District of Tennessee required a corrected motion after counsel disclosed AI-hallucinated citations, but declined to impose sanctions at that point. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

Apparently that AI program hallucinated over some citations. As a result, the Court required Plaintiff’s counsel to correct the citations and submit a Corrected Motion. They did so. (ECF No. 94.) The Sixth Circuit has recently addressed the role of AI in the realm of litigation. That court imposed significant sanctions and pointed out that …

2026-06-08 · United States District Court for the Northern District of Mississippi · provisional

On 2026-06-08, in Withers v. City of Aberdeen, the Northern District of Mississippi revoked pro hac vice admission, disqualified resident counsel, fined counsel $8,000, and referred the matter to bar authorities. Counsel filed opposition papers using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

On December 10, 2025, the Court entered an Order to Show Cause [110] directing all counsel of record in this case to show cause as to why the Court should not impose sanctions against them pursuant to Rule 11 of the Federal Rules of Civil Procedure, the Court’s Local Rules, and/or its inherent authority for …

2026-06-04 · Supreme Court of the State of Oregon · provisional

On 2026-06-04, in Mary McGreevy v. Adam Witkin, Supreme Court of Oregon struck the response to the petition for review, imposed a $500 sanction, and granted judicial notice. A self-represented appellant filed a response using nonexistent or hallucinated authorities. The monetary component was $500.

Petitioner on review filed a reply to the response that argued, among other things, that respondent on review’s "response relies on authorities that cannot be located in the Oregon Reports." On March 26, 2026, respondent on review filed a response to the reply that addressed petitioner's other arguments but did not address the assertion about …

2026-06-03 · United States District Court for the Western District of North Carolina

On 2026-06-03, in Wayne K. Smith, Sr. v. Polk County, et al, the Western District of North Carolina ordered plaintiff's counsel to show cause about two fabricated quotations and compliance with the court's AI-use standing order. Counsel filed an opening brief using quotations that did not appear in the cited source.

Artificial Intelligence The Defendants contend that the Plaintiff’s memorandum in support of the instant motion contains two fabricated quotations, along with multiple quoted statements lacking citation to any authority, and that such deficiencies suggest that the memorandum was drafted using artificial The Plaintiff complains that the Defendants tookthe “position” throughout discovery “that neither the vehicular …

2026-06-03 · United States District Court for the Western District of Missouri

On 2026-06-03, in Euphoric, LLC et al. v. Westport Community Improvement District, et al, the Western District of Missouri admonished the filer to verify authorities before presenting AI-assisted or otherwise unsupported legal citations. Counsel filed a motion using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

whatever the root cause for these inaccuracies and errors (including any use of legal or non-legal generative AI tools, for example), the professional duty and responsibility of counsel ... requires that careful and proper attention to detail is provided

2026-06-02 · United States District Court for the Western District of Washington · provisional

On 2026-06-02, in Fadi El Bitar v. Julio Hernandez, the Western District of Washington imposed a $1,000 monetary sanction for the defective legal authorities. Counsel filed a petition using quotations that did not appear in the cited source. The monetary component was $1,000.

10) contained citation errors which appeared to be “the result of using generative artificial intelligence without checking the citations generated by the program.” Dkt. 12 at 3. The Court ordered Petitioner’s counsel to show cause as to why they should not be sanctioned pursuant to Rule 11. Id. at 3–4. Within 24 hours, Julian Mansoor …

2026-06-02 · United States District Court for the Western District of Tennessee

On 2026-06-02, in Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al, the Western District of Tennessee ordered Reaves Law Firm to pay costs for improper citations and directed counsel to send the order to professional regulators. Counsel cited Press v. Vanderbilt University even though the court found the authority did not exist.

Specifically, Defendants’ response to RLF’s Partial Motion to Dismiss asserts that Plaintiff relies on cases that do not stand for the propositions for which they are cited, and, even worse, RLF includes quotations from those cases that do not exist. (See ECF No. 19.) Two days after Defendants initially raised the GAI issues, RLF filed …

2026-06-01 · United States Court of Appeals for the Seventh Circuit

On 2026-06-01, in Heriberto Perez-Castillo v. Todd W. Blanche, the Seventh Circuit sanctioned counsel for appellate expenses, admonished him, and referred the matter for possible discipline. Counsel filed an opening brief using record or transcript quotations not found in the record, quotations that did not appear in the cited source, and authorities used for propositions they did not support.

Perez-Castillo’s opening brief was riddled with AI hallucinations. These included two 2 No. 25-1988 dozen fabricated quotations, seven cases wrongly identified as precedent from this circuit, erroneous legal propositions, and assertions of fact flatly contradicted by the record. Counsel for Perez-Castillo, Abdullah Salah, blamed these errors on another attorney with whom he had contracted to …

2026-05-29 · United States District Court for the District of Colorado

On 2026-05-29, in Garcia v. City of Monte Vista, Colorado et al, the District of Colorado ordered counsel to show cause why sanctions should not issue for relying on an allegedly fabricated autopsy and forensic report. Counsel filed a motion using quotations that did not appear in the cited source and nonexistent or hallucinated authorities.

The Court is deeply concerned that counsel’s citation to Miller is a product of the un-verified work of generative artificial intelligence. The Court will separately enter an order to show cause on this matter.

2026-05-28 · Supreme Court of the State of New York, New York County · 2026 WL 1587346 · provisional

On 2026-05-28, in Strategic Funding Source, Inc. v. STI-NY, LLC, Supreme Court of New York awarded $2,000 in costs or fees caused by the defective legal authorities. Counsel filed a motion using authorities used for propositions they did not support.

*1 Editor's Note: This document contains discussion of unverified citations, likely generated by AI tools used by a party or counsel. These citations are not attributable to the Court. The unverified citations have been preserved as part of the official record, but links are unavailable. Part 11M Motion Date 02/12/2026 Motion Seq. No. 002 Decision …

2026-05-28 · Appellate Court of Illinois, First District, Fourth Division · 2026 IL App (1st) 250013-U

On 2026-05-28, in In re M.H., M.L., and M.H., Minors, Appellate Court of Illinois, First District ordered mother to show cause within fourteen days why sanctions should not be imposed for fictitious authorities. Counsel filed a response using nonexistent or hallucinated authorities and authorities used for propositions they did not support.

The Public Guardian points out that, throughout her brief, the Mother misstates the facts or holdings of cases she citedinsupportofherarguments,incorrectlycitesothers,and referencescasesthatdonotexist.ThePublicGuardianargues that the Mother's reliance on fictitious case holdings violates Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020) and asks us to find the Mother's arguments forfeited. “ ‘[B]ecause the merits of the case …

2026-05-27 · Supreme Court of the State of Oklahoma · 2026 OK 37

On 2026-05-27, in State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves, Supreme Court of Oklahoma publicly reprimanded the attorney as reciprocal discipline for ChatGPT-generated citations used in federal filings. Counsel filed a motion using authorities used for propositions they did not support.

1-A, Complainant, Oklahoma Bar Association, caused documentation to be transmitted to the Chief Justice of this Court following public reprimand and public censure in the states of Texas, Tennessee, and Alabama based on a sanctions order in the United States District Court for the Northern District of Alabama for using generative artificial intelligence to fabricate …

2026-05-27 · District Court of Appeal of the State of Florida, Fourth District

On 2026-05-27, in Innocent v. Meraki Installers, LLC, District Court of Appeal of Florida, Fourth District affirmed and referred counsel to the Florida Bar over trial-transcript quotations not found in the record. Counsel filed an initial brief using record or transcript quotations not found in the record, quotations that did not appear in the.

We write briefly, however, to address concerns regarding multiple quotations from the trial transcript contained in Appellant’s initial brief that do not appear to be found anywhere in the actual trial transcript or otherwise in the Record. In consideration of the arguments made on this point in the parties’ briefs, as well as during oral …

2026-05-27 · District Court of Appeal of the State of Florida, Fourth District

On 2026-05-27, in Eclectic Synergy, LLC v. Seredin, District Court of Appeal of Florida, Fourth District ordered counsel to show cause why sanctions should not issue for an apparently AI-generated emergency stay motion. Counsel filed a response using several nonexistent or hallucinated authorities and authorities used for propositions they did not support.

We denied the “emergency” motion for stay,1 and issued an order requiring counsel to show cause why sanctions should not be imposed because the petition appears AI-generated and raises frivolous arguments, misstates the law, and cites non-existent caselaw. Fla. R. App. P. 9.410(a). As an example, we quoted page 5 of the petition, which argues: …

2026-05-27 · United States District Court for the District of Delaware · provisional

On 2026-05-27, in Williamson v. Meyers (derivatively on behalf of Equinix, Inc.), the District of Delaware warned counsel after plaintiff conceded a fictitious citation and withdrew it from the briefing. Counsel filed a motion using at least one nonexistent or hallucinated authority.

CONCLUSION10 10 In reviewing Plaintiffs briefing, the Court identified at least one existence where Plaintiffhad cited to a non-existent authority and brought this issue to Plaintiffs attention. After investigating, Plaintiffconceded that this fictitious citation was most likely the result of artificial intelligence (“Al”). The Court has not considered any ofPlaintiffs contentions, to the extent that …

2026-05-22 · Sixth District Court of Appeal of Florida

On 2026-05-22, in Kings Roofing v. Fusion Works, District Court of Appeal of Florida, Sixth District ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed an initial brief using quotations that did not appear in the cited source, several nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

McCommon, Esquire, who, in his Initial Brief, has provided this Court with citations to several cases, some of which appear to be fabricated. The Initial Brief looks as if it was drafted with the assistance of generative artificial intelligence without Mr. McCommon having put sufficient safeguards in place to ensure the existence or accuracy of …

2026-05-21 · United States District Court for the Middle District of Pennsylvania

On 2026-05-21, in Twigg v. BSN Sports, Inc., et al, the Middle District of Pennsylvania ordered the filer to show cause why sanctions should not issue for the defective authorities. Counsel filed a motion using quotations that did not appear in the cited source, multiple nonexistent or hallucinated authorities, and authorities used for propositions they did not support.

The proliferation and availability of artificial intelligence (“AI”) tools and the ease with which litigants and attorneys can use them has caused an increase in citations to fictitious cases, quotations that do not appear in cases, and cases that do not support the propositions advanced.

2026-05-21 · United States District Court for the Western District of Oklahoma

On 2026-05-21, in Dalton Gage Hill v. Oklahoma County Criminal Justice Authority, the Western District of Oklahoma magistrate judge recommended denying the motion to vacate and described earlier Rule 11 sanctions proceedings against counsel. Counsel filed a response using quotations that did not appear in the cited source, nonexistent or hallucinated authorities, and authorities used for.

McBride to appear before the Court to show cause as to why sanctions should not be imposed under Rule 11 and the Court's inherent authority for citing fictitious cases in his response to Defendant Logan's motion to dismiss. See Doc. 126. 2. On September 5, 2025, the undersigned recommended Mr. McBride pay Defendants' reasonable attorneys' …

2026-05-21 · District Court in and for Tulsa County, State of Oklahoma · provisional

On 2026-05-21, in In re the Marriage of Amy Haddock and Justin Blu Haddock, the Tulsa County district court sanctioned counsel $2,000, ordered attorney-fee proceedings, required a knowledge-base audit, and directed bar referral. Counsel filed a motion using authorities used for propositions they did not support.

Husband's Motion containedthree citations to nonexistent lawand three citations to cases with inaccurate descriptions ofthe propositions oflawfor which they stood. The errant citations were pointed out to Mr. Johnson on August 25, 2025, at which point the parties agreed to pass that day's setting. This Court was not the assigned Judge at that time and …

2026-05-21 · United States District Court for the Northern District of Alabama · provisional

On 2026-05-21, in Jackie L. Miller v. Regions Bank, the Northern District of Alabama disqualified counsel from the case and from appearing before the judge for six months and referred the order to bar authorities. Counsel submitted a filing using quotations that did not appear in the cited source.

Attorney H. Gregory Harp ... following Attorney Harp’s misuse of generative artificial intelligence to make false statements to the court. ... the court draws an adverse inference ... that ChatGPT generated the four false quotations

2026-05-20 · United States District Court for the Southern District of Indiana

On 2026-05-20, in Davis v. Marion County Juvenile Detention Center, the Southern District of Indiana magistrate judge recommended a $2,000 sanction against counsel for two AI-generated non-existent citations. Counsel filed a motion using multiple nonexistent or hallucinated authorities and authorities used for propositions they did not support.

The Magistrate Judge has recommended that the Undersigned personally sanction Plaintiff’s counsel, Tae Sture, for including two non-existent legal citations in a brief responding to a motion to compel. The legal citations were hallucinations generated by an artificial intelligence (“AI”) research tool. The Magistrate Judge found Mr. Sture’s conduct violated the Indiana Rules of Professional …

2026-05-20 · United States District Court for the Eastern District of California

On 2026-05-21, in That Xiong v. Minga Wofford, the Eastern District of California declined sanctions in light of remedial steps but required counsel to verify all future case and record citations. Counsel cited G.A.A. v. Chestnut, No. 1:25-cv-01102-EPG, 2025 WL 3030589 (E.D. Cal. Nov. 21, 2025) even though the court found the authority did not exist.

Petitioner was ordered to provide in his OSC response signed declarations from Petitioner’s counsel, law student Gina Herrera, and any and all other staff who assisted Petitioner’s counsel regarding compliance with the Court’s January 13, 2026 Order; a detailed description of how the hallucinated citations were included in Petitioner’s reply brief at ECF No. 12; …

2026-04-21 · Supreme Court of Puerto Rico · 2026 TSPR 41; 218 DPR ___

The Supreme Court of Puerto Rico on 2026-04-21 admonished counsel for unverified or fabricated authorities and cautioned against repeating the citation misconduct in In re: María V. Irizarry Centeno; Anissa M. Bonilla Irizarry. Counsel filed a submission with six fabricated case citations, including Otero-Burgos v. Inter Med. Supplies.

Supp. 3d 443 (2023), constituye el primer caso donde se analizó extensamente el uso de inteligencia artificial generativa para producir citas ficticias y donde se impusieron sanciones detalladas por el mal uso de ChatGPT en un escrito judicial. 2 En lo concerniente a la conducta sancionable específica, el Tribunal de Distrito para el Distrito Sur …

2026-04-09 · United States Bankruptcy Court for the Western District of Louisiana

On 2026-04-09, U.S. Bankruptcy Court for the Western District of Louisiana struck counsel’s objection and supplemental response, imposed a $2,750 sanction, ordered AI-focused CLE, and barred further filings until compliance. Counsel submitted a filing with nonexistent or misstated legal provisions, fabricated or nonexistent authorities and mischaracterized authorities, including In re Garcia and In re Buttermilk Towne LLC.

the underlying promissory note.” 2 Regardless of what Ms. Wilson may have intended by citing to In re Garcia, the Court finds that her failure to review and verify the AI-generated Objection caused her to file a false and misleading pleading in this Court. Ms. Wilson also acknowledges that her Supplemental Response (ECF # 67) …

2024-02-22 · United States District Court for the Southern District of New York · provisional

On 2024-02-22, the Southern District of New York awards IDEA attorneys’ fees but reduces the requested hourly rates and hours. The court rejects the Cuddy Law Firm’s ChatGPT-4 fee-rate cross-check, citing citation hallucination cases and warning against using ChatGPT in future fee applications.

The Cuddy Law Firm also states that its requested hourly rates are supported by feedback it received from the artificial intelligence tool “ChatGPT-4.” Pl. Mem. at 16; see also Dkt 19 (“Kopp Decl.”). In fairness, the Cuddy Law Firm does not predominantly rely on ChatGPT-4 in advocating for these billing rates. It instead presents ChatGPT-4 …