Incident Tracker / United States (state)
TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor, No. SC21183 (Conn.)
·Connecticut Supreme Court·US-STATESanctions
The Connecticut Supreme Court, addressing AI hallucinations for the first time, sanctioned a landlord's lawyer whose Lexis-verified briefs acquired fabricated citations when he pasted them into ChatGPT for editing. It ordered six hours of CLE, a USD 1,000 payment to the Connecticut Bar Institute, a compliance report and a courtesy copy to the grievance committee, crediting his candour.
- Court
- Connecticut Supreme Court
- Date
- 2026-07-31
- Who used the AI
- Lawyer
- AI tool
- ChatGPT (used to edit briefs after Lexis research)
- Conduct
- Attorney Ian G. Gottlieb of GLG Law filed certification applications and briefs in two public-interest landlord-tenant appeals containing about seven hallucinated citations. He had researched on Lexis, then pasted the drafts into ChatGPT for editing, which added or altered case citations. He admitted a Rule 1.1 competence violation.
- Outcome
- Sanctions
- Penalty
- US$1,000
- Regulatory outcome
- Statewide Grievance Committee (Connecticut): The court ordered a courtesy copy of its sanctions order sent to the Committee and the order posted on the Judicial Branch website; no formal referral or Committee disposition on record. (2026-07-31)
- Status
- Verified against listed sources
- Last checked
- 2026-09-03
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor, No. SC21183 (Conn.)”, safelegalai.com/tracker/tov-realty-v-suarez (accessed 2026-09-04). Data: CC BY 4.0.