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TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor, No. SC21183 (Conn.)

·Connecticut Supreme Court·US-STATESanctions

The Connecticut Supreme Court 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, USD 1,000 each from counsel and the firm 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$2,000
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
2026-09-05

What was fabricated or misused

  • Approximately seven erroneous and unverified citations in the public-interest appeal applications and briefs; the order did not enumerate each citation

What the court said

“We are required to confront for the first time a lawyer’s use of generative artificial intelligence (generative AI) that has resulted in the submission of written materials to this court containing citations that were “hallucinated”—in other words, fabricated or inaccurately generated.”
Connecticut Supreme Court, slip op. at 1
“Unbeknownst to Attorney Gottlieb, the drafts produced by ChatGPT added new case citations or altered existing case citations, making the final documents filed in this court inaccurate and misleading.”
Connecticut Supreme Court, slip op. at 2
“He admitted, through counsel, that he filed documents in these matters containing a total of seven erroneous and unverified citations that resulted from the use of generative AI in the editing and review process.”
Connecticut Supreme Court, slip op. at 3
“We emphasize that this courtesy copy is not a referral for further disciplinary action.”
Connecticut Supreme Court, slip op. at 6

Timeline

  1. Superior Court AI verification rule, Practice Book § 4-9, took effect.
  2. Court held the show-cause hearing over hallucinated citations.
  3. Appellate AI rule amendments, including Practice Book § 62-6(d), took effect.
  4. Court imposed CLE, donation, compliance-report, and courtesy-copy sanctions.

Why this case matters

TOV is the Connecticut Supreme Court’s first sanctions order for a lawyer’s generative-AI citations. It differs from Barteca and In re Booker because the original research had been checked in Lexis before ChatGPT was used as an editor, and the court found no intent to deceive. The sanction still required extra CLE, two USD 1,000 donations, a compliance report, posting on the Judicial Branch website, and a courtesy copy to the grievance committee. The record shows that editing tools can alter citations after a valid research pass.

Practice note

Re-check citations after AI editing, even if the pre-edit draft was verified in Lexis or Shepard’s. Compare the final filed PDF against the source for every citation, quotation, and parenthetical. Connecticut filings also require compliance with Practice Book §§ 4-9 and 62-6(d), which require independent verification of AI-produced citations, authorities, and evidence.

Primary sources for this incident

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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 2026-10-07). Data: CC BY 4.0.

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