Incident Tracker / United States (federal)
Booker v. The Kroger Co., No. 1:26-cv-02006-SDG (N.D. Ga.)
·US District Court for the Northern District of Georgia, Atlanta Division·US-FEDFine
The US District Court for the Northern District of Georgia fined employment plaintiff's lawyer Christopher Johnson USD 8,000, payable to the court's sanctions fund, for citing four nonexistent or misrepresented authorities. Judge Grimberg found his show-cause response evasive and an attempt to shift blame to opposing counsel, required proof of ethics and technology CLE, and reserved further sanctions.
- Court
- US District Court for the Northern District of Georgia, Atlanta Division
- Date
- 2026-08-28
- Who used the AI
- Lawyer
- AI tool
- Not identified in the record
- Conduct
- Plaintiff's counsel Christopher Johnson cited four authorities that were nonexistent or misrepresented. At the show-cause hearing he denied using AI, which the court found lacked credibility and was evasive, and he devoted half of his written response to attacking opposing counsel.
- Outcome
- Fine
- Penalty
- US$8,000
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
What was fabricated or misused
- four purported cases highlighted in ECF 53 — the sanctions order described them as fake, false, and misleading but did not list their names
- misrepresentations of the content of real case authorities in plaintiff's filings — the sanctions order did not enumerate each authority
What the court said
“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.”
“You can use whatever AI tools you like, but only human beings will be held responsible for the outcome.”
“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.”
Timeline
- At the hearing, counsel denied using AI tools to prepare briefs.
- Counsel’s show-cause response acknowledged that he consulted AI tools.
- Court imposed an $8,000 fine and ordered CLE documentation.
Why this case matters
Booker adds a stronger culpability finding than most hallucinated-authority orders. Unlike Mata v Avianca, where the sanction targeted invented cases and post-challenge persistence, this order doubled a per-authority fine because the court found counsel lied when asked about AI use. It also enforced a standing order that allowed AI but placed responsibility on human filers. Compared with Williams v DFW Airport Board, decided one day earlier, Booker moved beyond warning to a court-registry fine and required proof of ethics and technology CLE.
Practice note
If a judge asks whether AI tools were used, answer directly and correct any earlier filing at once. Before filing, verify each authority and each proposition against a primary legal source. A standing order that permits AI still leaves the lawyer responsible for every factual and legal error in the filed paper.
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Booker v. The Kroger Co., No. 1:26-cv-02006-SDG (N.D. Ga.)”, safelegalai.com/tracker/booker-v-kroger (accessed 2026-10-07). Data: CC BY 4.0.