Legal AI incidents in the US state courts
As of 2026-10-07, the tracker records 54 incidents in the US state courts where AI misuse affected legal proceedings, from 2023-07-19 to 2026-10-07. 18 have a recorded regulatory or disciplinary disposition and 21 records carry a monetary penalty.
- 54
- incidents
- 18
- regulatory outcomes
- 21
- monetary penalties
- 20
- sanctions outcomes
- 2026-10-07
- latest decision
| Case | Jurisdiction | Who | AI tool | Consequence | ||
|---|---|---|---|---|---|---|
| Kid International, LLC v. City National Bank of Florida, No. 4D2025-2599 (Fla. 4th DCA 2026)District Court of Appeal of Florida, Fourth District | US-STATE | Lawyer | generative AI (unspecified) | Sanctions | — | |
| Tapscott v. Fariss, No. 25-1666 (Iowa Ct. App. 2026)Court of Appeals of Iowa | US-STATE | Litigant in person | — | Dismissal | — | |
| Washington v. Justice, No. 2D2025-2678 (Fla. 2d DCA 2026)District Court of Appeal of Florida, Second District | US-STATE | Litigant in person | generative AI (unspecified) | Dismissal | — | |
| Shannon v. Shannon, 322 Neb. 451 (2026), No. S-25-546Nebraska Supreme Court | US-STATE | Litigant in person | Generative AI (admitted; tool unnamed) | Filing struck | — | |
| Cervantes v. Bianco, No. S295866 (Cal. Sept. 24, 2026)Supreme Court of California | US-STATE | Lawyer | AI tools (unspecified) | Regulatory referral | The Supreme Court referred the matter to the State Bar of California to determine whether discipline is warrant… | |
| R. M. v. Mohr, 353 Or App 182 (2026), A188092Oregon Court of Appeals | US-STATE | Litigant in person | Artificial intelligence (admitted; tool unnamed) | Fine | US$250 | |
| Eric Posey v. Summer Bushnell, Docket No. 52072 (Idaho 2026)Idaho Supreme Court | US-STATE | Litigant in person | generative AI (suspected) | Warning | — | |
| Lisandrillo v. Palozzi, No. 4D2026-2262 (Fla. 4th DCA)District Court of Appeal of Florida, Fourth District | US-STATE | Lawyer | — | Pending | — | |
| Asiedu v. Eastlund, Nos. A25-2106, A26-0532 (Minn. Ct. App.)Minnesota Court of Appeals | US-STATE | Litigant in person | — | Sanctions | US$2,341.25 | |
| State ex rel. Schnell v. Richardson, No. ED114731 (Mo. Ct. App.)Missouri Court of Appeals, Eastern District | US-STATE | Lawyer | — | Sanctions | US$1,750 | |
| Douglas v. Deutsche Bank National Trust Co., No. 24-CV-1099 (D.C. Ct. App.)District of Columbia Court of Appeals | US-STATE | Lawyer | Google generative AI search tool | Regulatory referral | The Court of Appeals struck appellee's brief and referred the matter to the Office of Disciplinary Counsel for… | |
| State v. Presti, No. CAAP-24-0000826 (Haw. Ct. App.)Hawaii Intermediate Court of Appeals | US-STATE | Litigant in person | — | Warning | — | |
| Noble v. WMC Mortgage Corp., 2026 IL App (1st) 251168-UAppellate Court of Illinois, First District | US-STATE | Litigant in person | — | Warning | — | |
| Kiser v. DeSimone Auto Group, No. 2428 EDA 2025 (Pa. Super. Ct.)Superior Court of Pennsylvania | US-STATE | Lawyer | — | Warning | — | |
| Salloum v. Department of Transportation, No. 25CA1748 (Colo. App.)Colorado Court of Appeals | US-STATE | Litigant in person | — | Warning | — | |
| Varma v. The Bank of New York Mellon, No. E085566 (Cal. Ct. App.)California Court of Appeal, Fourth Appellate District, Division Two | US-STATE | Litigant in person | — | Sanctions | The court directed the clerk to send a copy of the opinion to the State Bar for investigation of possible unaut… | |
| Benjamin v. State, No. 2189 Sept. Term 2024 (Md. App. Ct.)Appellate Court of Maryland | US-STATE | Lawyer | — | Warning | — | |
| LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC, Record No. 1407-25-4 (Va. Ct. App.)Court of Appeals of Virginia | US-STATE | Lawyer | — | Sanctions | — | |
| Capital Standard, LLC v. U.S. Bank National Association, No. 2D2024-1392 (Fla. 2d DCA)Florida Second District Court of Appeal | US-STATE | Lawyer | generative AI (unspecified) | Fine | US$1,500 · Court referred counsel to The Florida Bar. No disposition on record. | |
| In re Faisal S. Ahmed (Minnesota attorney discipline)unverifiedSupreme Court of Minnesota (stipulated attorney discipline) | US-STATE | Lawyer | — | Suspension | 30-day suspension by stipulation, reported 21 August 2026; the Supreme Court order has not been located. | |
| In re Stephen Aarons (Supreme Court of New Mexico, murder appeal; case number not located)unverifiedSupreme Court of New Mexico | US-STATE | Lawyer | ChatGPT (per counsel's account) | Sanctions | US$5,000 · Court referred counsel to the Disciplinary Board (per Santa Fe New Mexican report). No disposition on record. | |
| JMOR Properties, LLC v. Artist Alley Townhomes, LLC, No. 4D2026-1787 (Fla. 4th DCA)Florida Fourth District Court of Appeal | US-STATE | Lawyer | — | Regulatory referral | Court referred counsel to The Florida Bar under Fla. R. Gen. Prac. & Jud. Admin. 2.515(d)(2) and Bar Rule 3-7.1… | |
| Elliott v. New York Bariatric Group, LLC, No. AAN-CV-25-6066141-S (Conn. Super. Ct.)unverifiedConnecticut Superior Court, Judicial District of Ansonia-Milford | US-STATE | Litigant in person | — | Other | — | |
| Kleyman Law Group, P.C. v. Kaloidis, Index No. 502644/2025 (N.Y. Sup. Ct., Kings County)Supreme Court of the State of New York, Kings County | US-STATE | Lawyer | Claude and other generative AI platforms (per hearing testimony) | Sanctions | US$46,511 · The order refers Alex I. Kleyman to the State of New York Grievance Committee for the Second, Eleventh and Thir… | |
| Southland Homes & Real Estate and Investment, LLC v. Lam, No. 30-2026-01569207 (Cal. Super. Ct. App. Div., Orange County)Superior Court of California, County of Orange, Appellate Division | US-STATE | Lawyer | ChatGPT and Google Gemini | Sanctions | US$4,000 · The appellate division directed the clerk to serve the sanctions order on the State Bar after remittitur and or… | |
| Mendel S. v. Faigy S., 2026 NY Slip Op 26118 (Fam. Ct., Kings County)Family Court of the State of New York, Kings County | US-STATE | Lawyer | — | Sanctions | US$1,000 | |
| TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor, No. SC21183 (Conn.)Connecticut Supreme Court | US-STATE | Lawyer | ChatGPT (used to edit briefs after Lexis research) | Sanctions | US$2,000 · The court ordered a courtesy copy of its sanctions order sent to the Committee and the order posted on the Judi… | |
| Scott v. Illinois Human Rights Commission, 2026 IL App (1st) 251462Appellate Court of Illinois, First District | US-STATE | Lawyer | ChatGPT (per counsel's response to the court) | Fine | US$15,000 · At paragraph 82 the court directed the clerk of the Appellate Court, First District, to send a copy of the opin… | |
| Gouldy v. Chiasson, No. 4D2025-1289 (Fla. 4th DCA)Florida Fourth District Court of Appeal | US-STATE | Litigant in person | — | Pending | — | |
| Dineen/Shibata v. Kotchka, No. 1 CA-CV 25-0606 PB (Ariz. Ct. App.)Arizona Court of Appeals, Division One | US-STATE | Not recorded | — | Sanctions | — | |
| Del Biaggio v. Bansen, No. A174647 (Cal. Ct. App., 1st Dist., Div. 4)California Court of Appeal, First Appellate District, Division Four | US-STATE | Lawyer | — | Fine | US$1,500 | |
| Leiske v. Kidd, C.A. No. 2025-0426-CDW (LWW) (Del. Ch.)Court of Chancery of Delaware | US-STATE | Not recorded | — | Other | — | |
| State ex rel. Oklahoma Bar Association v. Reeves, 2026 OK 37Supreme Court of Oklahoma | US-STATE | Not recorded | ChatGPT | Warning | Public reprimand by the Supreme Court of Oklahoma (27 May 2026) under reciprocal discipline, following a Texas… | |
| Gleason v. Marcus, No. 2D2024-2688 (Fla. 2d DCA)Florida Second District Court of Appeal | US-STATE | Not recorded | — | Warning | — | |
| Ibach v. Stewart, No. SC-2025-0106 (Ala.)Supreme Court of Alabama | US-STATE | Not recorded | — | Sanctions | US$17,200 · The Supreme Court of Alabama referred Hall to the Alabama State Bar for potential discipline over possible viol… | |
| Prososki v. Regan, 321 Neb. 38 (2026)Nebraska Supreme Court | US-STATE | Not recorded | — | Regulatory referral | Appellant's counsel W. Gregory Lake was referred for investigation of potential violations of the Rules of Prof… | |
| State v. Coleman, 2026-Ohio-965 (Ohio Ct. App., 11th Dist.)Ohio Court of Appeals, Eleventh Appellate District | US-STATE | Not recorded | ChatGPT | Sanctions | US$2,000 · The court referred counsel's conduct to the Office of Disciplinary Counsel of the Supreme Court of Ohio for inv… | |
| Cassata v. Michael Macrina Architect, P.C., 2026 NY Slip Op 26014New York Supreme Court, Suffolk County | US-STATE | Not recorded | generative AI (AI-enhanced Westlaw) | Sanctions | US$10,000 | |
| Deutsche Bank Natl. Trust Co. v. LeTennier, 2026 NY Slip Op 00040 (App. Div. 3d Dept.)New York Supreme Court, Appellate Division, Third Department | US-STATE | Not recorded | generative AI (unspecified) | Sanctions | US$10,000 | |
| Mezu v. Mezu (Md. App. Ct. 2025), No. 361 Sept. Term 2025Appellate Court of Maryland | US-STATE | Not recorded | ChatGPT | Regulatory referral | The court referred the attorney to the Maryland Attorney Grievance Commission based on the nature and severity… | |
| In re R.A. (Iowa Ct. App. 2025), No. 24-1629Court of Appeals of Iowa | US-STATE | Not recorded | AI-driven research tools (unspecified) | Regulatory referral | US$150 · The court struck the reply brief, imposed a $150 penalty (or two hours of AI-ethics CLE in lieu), and directed… | |
| Bethany Cingel v. Gregory Ferreri (Ind. Ct. App. 2025), No. 25A-DC-00500Court of Appeals of Indiana | US-STATE | Not recorded | generative AI (suspected) | Warning | — | |
| Noland v. Land of the Free, L.P., No. B331918 (Cal. Ct. App.)California Court of Appeal, Second Appellate District | US-STATE | Not recorded | generative AI (unspecified) | Sanctions | US$10,000 · The court directed the clerk of the court to serve a copy of its opinion on the State Bar of California, referr… | |
| Kurt Williams v. Karin Kirch (Ind. Ct. App. 2025), No. 25A-SC-00196Court of Appeals of Indiana | US-STATE | Not recorded | generative AI (suspected) | Warning | — | |
| Robert Dastou v. Kathryn Holmes, No. 2381CV02212 (Mass. Super. Ct.)Massachusetts Superior Court | US-STATE | Not recorded | ChatGPT | Sanctions | — | |
| Nimat Shahid v. Sufyan Esaam (Ga. Ct. App. 2025)Court of Appeals of Georgia | US-STATE | Lawyer | — | Fine | US$2,500 | |
| Garner v. Kadince, Inc., 2025 UT App 80Utah Court of Appeals | US-STATE | Not recorded | ChatGPT | Sanctions | US$1,000 | |
| An v. Archblock, Inc. (Del. Ch. 2025)Delaware Court of Chancery | US-STATE | Not recorded | generative AI (unspecified; court cited ChatGPT, Gemini, Copilot, CoCounsel as examples) | Other | — | |
| Dewald v. Massachusetts Mutual Life Ins. Co. (AI avatar at oral argument), App. Div. 1st Dept.unverifiedNew York Supreme Court, Appellate Division, First Department | US-STATE | Not recorded | AI-generated video avatar (tool not named) | Warning | — | |
| Al-Hamim v. Star Hearthstone, LLC, 2024 COA 128Colorado Court of Appeals | US-STATE | Not recorded | — | Warning | — | |
| Kruse v. Karlen, No. ED111172 (Mo. Ct. App., E.D.)Missouri Court of Appeals, Eastern District | US-STATE | Not recorded | — | Sanctions | US$10,000 | |
| Smith v. Farwell, No. 2282CV01197 (Mass. Super. Ct., Norfolk Cnty.)Massachusetts Superior Court, Norfolk County (Davis, J.) | US-STATE | Lawyer | — | Sanctions | US$2,000 | |
| Matter of Samuel, 2024 NY Slip Op 24014, 82 Misc 3d 616 (Sur Ct, Kings County 2024)New York Surrogate's Court, Kings County | US-STATE | Lawyer | — | Other | — | |
| Ex parte Allen Michael Lee, No. 10-22-00281-CR (Tex. App.—Waco July 19, 2023) (published)Texas Court of Appeals, Tenth District (Waco) | US-STATE | Lawyer | — | Other | — |
Cite as: SafeLegalAI Global Legal AI Incident Tracker, United States (state) view, safelegalai.com/tracker/us-state (accessed 2026-10-07). Data CC BY 4.0.
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