When AI citations
reach the lawyer.

Other

The Fifth Circuit vacated a preliminary injunction against a Mississippi education statute and ordered reassignment. The citation problem here arose in a district court's own orders, not in a party's filing. The majority reported that the original temporary restraining order named parties and declarations absent from the record and quoted language not found in the statute, and that the district judge later wrote that a law clerk had used AI to assist in drafting an earlier version docketed by mistake. It also reported that oral argument revealed the replacement order still cited a Fourth Circuit case, Cousins v. School Bd. of City of Norfolk, which the majority said does not exist and called an apparent AI hallucination. No tool was named and no sanction was imposed. One panel member concurred only in the last paragraph of the majority opinion.

Lawyer

The Fourth District Court of Appeal of Florida affirmed summary judgment on limitations grounds, then granted the defendants' sanctions motion. Its independent review found the initial brief cited Ogilvie v. Sebring Airport Authority seven times, a case the court called hallucinated and non-existent, attributed quotations to real opinions that do not contain them, and misstated holdings. Responding to an order to show cause, counsel admitted certain authorities did not exist as cited and said the firm used generative AI as one component of research and drafting, alongside materials supplied by the client; no specific tool was named. The court noted that the plaintiffs' earlier pro se complaint cited fifteen non-existent cases among thirty-two. It disregarded the affected citations, extended its sanction precedents to a party's motion under Rule 9.410(b), and awarded appellate attorney's fees in an amount not yet set.

Pro Se Litigant

The Second District Court of Appeal of Florida could not locate eleven cases cited in the initial brief of two self-represented appellants and ordered them to supply copies or show cause. They supplied no copies and described the citations as scrivener's errors. Their response neither admitted nor denied using generative AI; the court said AI was the likely source but that its concern was the reliance on what it called fictitious cases, whatever the source. No specific tool was named. The court held it could sanction without applying amended Rule 2.515(d)(2)(D) retroactively. Citing the citations, the response, and a pattern of frivolous filings across three proceedings, it stated that it dismissed the appeal and limited related future pro se filings to those signed by a Florida Bar member, apart from proceedings already pending. The opinion's closing line reads "Affirmed."

Pro Se Litigant

The Nebraska Supreme Court described a self-represented appellant's brief in a post-divorce contempt appeal as riddled with fabricated citations and quotations, and attributed them to the appellant's admitted use of generative AI; no specific tool was named. Applying Prososki v. Regan to self-represented parties, the court held that a brief with misstatements of law or nonexistent authority is sanctionable whether or not the party has counsel. Citing the novelty of the issue, it stopped short of dismissal, struck the brief, reviewed for plain error, found none, and affirmed. It warned that dismissal may follow in future cases. The $16,114.74 attorney fee award discussed in the opinion arose from the contempt proceeding, not the citations, and is not counted as a penalty here.

Pro Se Litigant

The Appellate Court of Illinois, First District, affirmed the dismissal with prejudice of a self-represented buyer's real estate claims. The trial court had found that one citation in her verified complaint and eight in her response to the motions to dismiss did not exist, called them "just a few" of the citations it could not verify, and named her "heavy reliance on AI-hallucinated cases" as an additional reason to deny further amendment. Both defendants had reported in reply briefs that they could not locate multiple cited cases. The appellate court affirmed on briefing deficiencies and an incomplete record, and imposed no separate sanction.

Pro Se Litigant

The Arkansas Court of Appeals dismissed a self-represented tenant's appeal from an unlawful detainer judgment. In addition to multiple Rule 4-2 briefing defects, the court stated that none of the cases cited in her brief exist, described them as fictitious, and said the brief seems to have been generated by artificial intelligence. The court held it could not evaluate arguments built on nonexistent precedent and that parties must confirm the existence and validity of the authorities they cite. No monetary sanction was imposed.

Pro Se Litigant

The Oregon Court of Appeals found that a self-represented respondent's opening brief in a restraining-order appeal cited three cases the court described as fabricated. It issued an order to show cause proposing a $1,500 sanction, or $500 per authority. The respondent admitted the citations resulted from his reliance on artificial intelligence, apologized, and accepted responsibility; no specific tool was named. Citing his acknowledgment and limited financial resources, the court reduced the sanction to $250, disregarded the cited authorities, and affirmed the trial court on the merits.

Pro Se Litigant

The Idaho Supreme Court affirmed a defamation judgment against a self-represented appellant whose briefing, it found, cited a case that does not exist under the given citation and two cases it could not locate. The court also found that only six of twenty-two purported quotations were accurate. It stated the nature of the errors suggests she may have relied on generative AI; she denied doing so, and the court said the record raised serious doubt about that denial. After ordering supplemental briefing on dismissal as a sanction, the court declined to rule on nine of her ten issues for inadequate briefing but imposed no sanction, noting the $1,176,000 judgment against her.

Lawyer · Google AI search tool

The District of Columbia Court of Appeals struck a mortgage trustee's appellate brief in a judicial foreclosure appeal after the court could not locate several cited cases. Responding to a show-cause order, one of the attorneys confirmed four cited authorities did not exist and stated she had used Google's generative AI search tool to locate case authority without verifying it. The firm said it was unaware of her use and that its policy bars AI drafting. The court held every attorney listed on the brief bears some responsibility, struck the brief, and referred the matter to the Office of Disciplinary Counsel. A concurrence noted this was the court's first reported brief with such citations.

Lawyer · Multiple (ChatGPT, Google Gemini)

The Appellate Division of the Orange County Superior Court sanctioned two attorneys for a petition for writ of supersedeas in an unlawful detainer appeal. The court stated two cited cases do not exist, one carried an incorrect page cite, and another was cited for a proposition it does not support. The drafting attorney admitted using ChatGPT and Google Gemini without verifying the authorities. The supervising attorney, listed as counsel of record, said he reviewed the arguments but not the citations; the court rejected that defense. It imposed $2,500 against him and $1,500 against the drafter, and directed service of the order on the State Bar. A modification order followed on August 5, 2026.

Lawyer · ChatGPT

The Appellate Court of Illinois, First District, sanctioned petitioner's counsel under Illinois Supreme Court Rule 375 after his briefs cited one case the court could not locate in any reporter, five real cases that do not contain the cited principle or quoted language, and four statutory quotations the court could not match to the applicable version of the statute. Responding to a show-cause order, counsel conceded the citations and stated he uses a premier corporate ChatGPT subscription and cross-referenced the citations in Lexis-Nexis but overlooked the errors. The court set a rate of $1,500 for each of the ten misstatements, ordered $15,000 paid to the clerk within 30 days, and directed the clerk to send the opinion to the Illinois Attorney Registration and Disciplinary Commission.

Pro Se Litigant

The Twelfth District Court of Appeals of Ohio addressed a self-represented father's acknowledged reliance on artificial intelligence in drafting his appellate brief. The court stated several citations were erroneous, leading to miscited cases and to cases that exist but stand for different legal propositions than the brief represented. The court reminded all parties and attorneys appearing before it that citations it cannot verify will be disregarded and may result in sanctions, and noted that pro se status does not relieve a litigant of the appellate rules. It imposed no penalty and resolved the appeal on other grounds.

Lawyer

The Tenth Circuit affirmed dismissal and separately addressed appellant counsel's opening brief, which cited one legal authority the court stated does not exist and characterized two real cases in ways the court found unsupported by the text of the opinions. The court assumed generative artificial intelligence produced the misrepresentations. Counsel conceded citation errors in reply but filed no corrected brief until a Notice of Errata the day after oral argument. The court held the filing was sanctionable conduct under 10th Cir. R. 46.5 but concluded the missteps did not merit sanctions, cautioning that counsel remains responsible for verifying authority no matter the technology used.

Pro Se Litigant

Florida's Fourth District Court of Appeal affirmed an appellate fee award and issued a separate order to show cause why the self-represented appellant should not be barred from further pro se filings. The court stated her initial brief cited a case that does not exist, attributed quotations to real Florida decisions that do not contain them, and relied on cases that do not support the propositions cited. In its conclusion the court described a growing pattern of self-represented filings that appear to be generated by artificial intelligence platforms and contain phantom authority, but it made no finding that this appellant used such a tool. She had been warned twice before against frivolous filings.

Pro Se Litigant

The Indiana Tax Court admonished self-represented petitioners whose motion to supplement the record cited court rules that exist but, in the court's words, plainly do not stand for any of the propositions advanced. In a section headed as a note on the use of artificial intelligence, the court stated this led it to believe the petitioners used generative AI to produce the motion. The court recognized the benefits of such tools for self-represented parties, restated the duty to independently verify the authenticity and accuracy of cited authority, and imposed no further penalties beyond the admonishment.

Pro Se Litigant

The Arizona Court of Appeals, Division One, affirmed and sanctioned a self-represented appellant under A.R.S. Section 12-349 and ARCAP 25 for an opening brief containing cases the court could not locate and misrepresentations of other authority. Ordered to show cause and testifying under oath, the appellant stated he relied on artificial-intelligence-assisted research tools and admitted taking no independent step to verify the authorities. The court held that citing an unverifiable case is sanctionable whether the filer is an attorney or self-represented, and awarded the appellee that portion of her reasonable attorney fees incurred because of the citations, plus costs, contingent on ARCAP 21 compliance.

Lawyer

The California Court of Appeal, First Appellate District, ordered appellant's counsel to pay $1,500 to the clerk of the court after his opening brief carried quotations the court could not locate in the cited opinions, including language attributed to a decision whose reporter citation matched a different case. Counsel's declaration stated his office uses generative AI with protocols requiring human verification and blamed a communication error with a paralegal. The court held the described protocol would not have satisfied State Bar guidance requiring the lawyer to review all AI outputs, ordered the opinion forwarded to the State Bar, and required counsel to give his client a copy and certify he had done so.

Lawyer

The Eleventh Circuit affirmed dismissal of a third amended complaint and addressed plaintiffs' counsel, whose opening brief relied on at least eight cases the court stated do not exist, including one attributed to the Eleventh Circuit itself. After the defendants identified the problem, counsel sought to withdraw eight listed cases, none of which matched the eight in the opening brief, and the court stated those eight were also not real. The court held that outsourcing legal work to artificial intelligence software is not competent representation and said the Chief Judge would refer the matter to the Committee on Lawyer Qualifications and Conduct by separate order.

Lawyer

The Eleventh Circuit affirmed summary judgment and granted the appellee's motion to strike portions of the reply brief, which the appellee showed cited two court opinions and at least five quotations that could not be located in the court's reporters. Ordered to supply supplemental briefing, counsel stated only that he had been unable to identify a verified source and did not explain how the citations reached the brief. The court said it suspected generative artificial intelligence, granted attorney's fees for the time spent on the motion with the amount reserved for a later order, and referred the attorney to the Committee on Lawyer Qualifications and Conduct.

Lawyer

The Delaware Court of Chancery ordered the signing attorney and his firm to show cause why they should not be sanctioned under Court of Chancery Rule 11(c) after an answering brief was found to contain citations and quotations that could not be located and legal propositions absent from the cited opinions. Counsel acknowledged using a generative AI tool to revise the brief and not verifying the output, attributing the lapse to a paralegal's review. The court noted the corrected brief removed quotation marks while leaving the descriptions uncorrected, held the duty to verify nondelegable, and required affidavits from counsel and the firm addressing its AI policies and cite-checking process.

Pro Se Litigant

The First District Court of Appeals of Ohio addressed a self-represented appellant whose brief cited two cases the court could not locate in any reporter, including one carrying an unusual three-party caption that corresponded to no real decision. The court stated the citations bore the hallmarks of AI hallucinations, while noting the appellant neither confirmed nor denied using generative artificial intelligence. Because the court's local rule governing AI use (Loc.R. 45) was not in effect when the brief was filed, the court declined to impose sanctions and denied the opposing party's sanctions motion as a matter of warning. The court separately denied a motion to declare the appellant a vexatious litigator.

Lawyer

After directing counsel to show cause under 22 NYCRR 130-1.1, the Appellate Division, Second Department imposed sanctions for an appellate brief that the court stated was prepared with the assistance of generative artificial intelligence and contained citations to nonexistent cases, purported Court of Appeals quotations contrary to actual law, and misrepresentations of what real cases held. Counsel submitted an affirmation taking full responsibility for the deficiencies and acknowledging that the nonexistent cases had been generated by AI. The court directed the attorney to pay $8,000 and the firm to pay $2,500 to the Lawyers' Fund for Client Protection of the State of New York, and noted that whether further disciplinary action is warranted is a matter for the Attorney Grievance Committee.

Lawyer

In a published opinion, the Michigan Court of Appeals affirmed the denial of the plaintiff's motion for a new trial and separately addressed plaintiff's counsel's repeated reliance on authority the court found to be unsupported or nonexistent. The court stated that counsel cited a case that does not exist and cited real authorities for propositions they do not support, and that a later Notice of Correction, itself prepared with the assistance of artificial intelligence, attributed quotations and legal propositions to cases that did not contain them. The court held this conduct violated MCR 7.216(C)(1) and MCR 1.109(E)(5), that sanctions were mandatory under MCR 1.109(E)(6), and remanded for the trial court to determine the actual damages and expenses, including reasonable attorney fees, to be paid by plaintiff's counsel personally. The amount was left for determination on remand.

Lawyer

The Indiana Court of Appeals affirmed a custody determination and addressed the appellee's request to sanction the appellant for citing fictitious authority. The appellant's counsel had informed the court that the initial brief contained citations to two cases that do not exist and attributed a fictitious quotation to a real case, then sought leave to file an amended brief, which the court granted. The appellee requested $5,000 in attorney's fees as a sanction. The court declined, finding monetary sanctions were not warranted because counsel had brought the errors to the court's attention and taken responsibility and the appellee had not shown resulting prejudice. The court echoed warnings from other courts about the risks of using artificial intelligence in litigation.

Lawyer

The court discharged its order to show cause without imposing sanctions or a bar referral, finding counsel's efforts and expressions of repentance (including a State Bar Journal article discussing their AI-citation errors) were made in good faith and sufficient, while noting the article fell short of a full treatment of the issue.

Lawyer

In a published decision, the California Court of Appeal, First Appellate District, affirmed sanctions the trial court had imposed on Lipeles Law Group, APC and its attorneys after the firm's opposition brief relied on citations the trial court found did not exist and on quotations the court found were fictitious and attributed to real but miscited cases. After issuing an order to show cause, the trial court imposed a sanction of $6,000 jointly and severally, with $5,000 payable to the defendants and $1,000 payable to the court. One attorney's declaration denied using AI or submitting any inaccurate citations, and the court observed it did not need to resolve the precise cause because the miscitations were sanctionable regardless. The Court of Appeal rejected the firm's challenges and affirmed.

Pro Se Litigant

In a child-custody appeal, the court stated it was troubled by the pro se appellant's citation to cases and quotations it characterized as fictitious throughout her appellate brief, observing that such hallucinated cases are typically a hallmark of irresponsible use of generative AI in legal drafting. The court cautioned her regarding any future filings; no penalty was imposed in this opinion.

Lawyer

The court noted inaccuracies and errors in plaintiffs' counsel's filings, including possible use of generative AI tools, and reminded counsel of their professional duty to verify the substance and form of legal authority presented. The court admonished counsel but imposed no monetary sanction in this order.

Lawyer

The Ninth Circuit panel imposed sanctions on attorneys Sethi and Rounds, whose briefs contained nonexistent cases, misattributed quotations, and misrepresentations of real cases that the panel attributed to generative AI hallucinations. The panel held the violation occurred at the point of signing and filing, ordered each attorney to pay $2,500 to the Clerk, suspended each from practice before the court for six months, imposed a two-year certification requirement on future filings, and directed the Clerk to serve the order on the State Bar of California.

Lawyer

The court found that plaintiff's counsel's memorandum contained quotations of legal authority that do not appear in the cited sources, which counsel did not directly deny were the product of AI hallucination. The court denied the underlying motion and directed counsel to show cause why she should not be sanctioned.

Lawyer · Google Gemini

Petitioner's counsel acknowledged that legal interns used Google Gemini to generate text containing quotations that do not exist and were presented as binding Ninth Circuit precedent. The court held the signing attorney responsible, imposed a $1,000 sanction payable to the Clerk, issued a public reprimand, and discharged the order to show cause.

Lawyer

The court found that plaintiff law firm Reaves Law Firm relied on generative-AI-assisted filings containing citations and quotations to authorities that could not be verified, in violation of Federal Rule of Civil Procedure 11. The court ordered the firm to reimburse defendants' costs and attorneys' fees for the responsive filings (amount to be set on a later accounting) and referred the matter to the Tennessee Board of Professional Responsibility's Disciplinary Counsel.

Lawyer · ChatGPT

The Seventh Circuit found that the petitioner's opening brief contained roughly two dozen quotations that do not exist, seven cases incorrectly identified as circuit precedent, and assertions contradicted by the record, which counsel attributed to ChatGPT. The court imposed a $5,000 fine on attorney Abdullah Salah under Federal Rule of Appellate Procedure 46(c), declined to sanction the contracted drafting attorney (Farah Chalisa) at that time, and referred the matter to the Illinois Attorney Registration and Disciplinary Commission.

Lawyer

In addressing the pleadings, the court noted that filings appeared to contain hallucinated legal authority obtained from generative AI tools and stated it would separately enter an order to show cause on that issue.

Pro Se Litigant

The court observed that a citation in the filings did not appear in the cited opinion and appeared to have been created by generative AI tools, noting that AI can be a tempting tool for pro se litigants. The court overruled plaintiffs' objections and cautioned that future improper filings could be struck or lead to dismissal.

Pro Se Litigant

The Public Guardian argued that the mother's appellate brief misstated holdings, miscited cases, and referenced cases that do not exist, in violation of Illinois Supreme Court Rule 341(h)(7). The court proceeded to decide the appeal on the merits and the record; no sanction is reported in the provided text.

Lawyer

After counsel responded to the court's order to show cause, the Fourth District Court of Appeal affirmed and referred counsel to The Florida Bar for appropriate action, finding that the petition cited a case (Citigroup Global Mkts., Inc. v. Masek) that does not exist in Florida and misstated the law, in violation of the duty of competence. The court did not impose a monetary sanction.

Lawyer

In this Florida Fourth District appeal, the court addressed counsel's filing containing improper citations and referred the matter for disciplinary review.

Pro Se Litigant

In two consolidated cases arising from a divorce proceeding, the court ordered the pro se petitioner to show cause why it should not stop accepting his pro se filings, and after considering his response concluded sanctions were appropriate. The opinion noted that cited cases did not support the arguments made and that litigants are responsible for AI-generated filings containing what the court described as fictitious authority or actual cases cited for inaccurate legal propositions.

Lawyer · ChatGPT

The Oklahoma Supreme Court considered reciprocal discipline after the respondent admitted, in a federal show-cause response, that citations in two motions were generated by ChatGPT, which the federal court held were not accurate statements of law. Texas and Alabama authorities had already imposed public reprimands for the same conduct.

Lawyer

After opposing counsel flagged a citation to a non-existent authority, plaintiff conceded the citation was most likely the result of AI. The court declined to consider any contentions resting on that authority and stated it would consider whether further action was necessary.

Pro Se Litigant

The appellate court found that five cases cited by the pro se litigant could not be located at the citations given, with some not located at all and the rest not containing the quoted language or supporting the propositions cited; the court stated they appeared to be the result of AI-generated hallucinations. When confronted, he affirmed the citations existed and criticized opposing counsel's diligence. The court affirmed the trial court's sanction against him and taxed the costs of the appeal.

Lawyer

The court identified a citation to a case that does not exist, along with quotations not found in real cases and mischaracterizations of law, in plaintiff's summary-judgment response. The court directed attorney Aaron Randall Rice to show cause why he should not be sanctioned under Rule 11.

Lawyer

After the appeal was dismissed, the court expressly retained jurisdiction to pursue possible sanctions against the appellant's counsel over authority in his initial brief. Counsel was ordered to file the cited cases with the court within ten days and to show cause why he should not be sanctioned and referred to The Florida Bar for potential discipline.

Lawyer

Although the appeal was dismissed by joint stipulation, the court retained jurisdiction over possible sanctions because the initial brief cited several cases that appear not to exist, apparently drafted with generative AI without adequate safeguards. The court directed attorney McCommon to show cause and referred the matter to The Florida Bar for potential discipline.

Lawyer

In a Report and Recommendation, a magistrate judge addressed counsel's repeated failure to disclose AI use and recommended Rule 11 sanctions, finding monetary sanctions appropriate given the costs of litigating the motion and counsel's failure to investigate and correct the amended complaint. The judge recommended ordering Mr. McBride to pay Defendant Winchester's reasonable attorney's fees (to be fixed on a later accounting) and recommended a contempt finding.

Lawyer

The court found that Mr. Johnson, husband's counsel, filed a motion containing three citations to nonexistent law and three citations mischaracterizing the propositions for which real cases stood. The court sanctioned Mr. Johnson $2,000, payable into the court fund within thirty days, declined to impose additional sanctions, and stated it would contact the Oklahoma Bar Association about the order.

Lawyer

In ongoing disciplinary proceedings, the court addressed what it found to be attorney H. Gregory Harp's misuse of generative AI to make inaccurate statements to the court and his efforts to conceal that use. The court's measures included disqualifying him from the case, suspending him from practice in the Northern District of Alabama, and referring the matter to the Alabama State Bar.

Pro Se Litigant

In a criminal appeal, the court found the pro se appellant's cited cases either did not support the propositions for which they were cited or were, in the court's words, apparent fabrications, very possibly hallucinated cases generated by artificial intelligence services. The court declined to consider the propositions supported by those citations and affirmed the judgment; no sanction was imposed.

Lawyer

The court addressed an order to show cause arising from hallucinated citations in petitioner's reply brief and counsel's failure to comply with a prior order. Considering the early-career involvement of a law student, the court discharged the OSC and declined to impose sanctions, repeating its admonishment that AI tools must be used responsibly.

Lawyer

The court found that counsel's brief cited cases that do not exist, cited real but unrelated cases, and quoted language that does not appear in the cited opinions. The court denied most of the omnibus motion and directed Mr. Mattiacci to show cause why he should not be sanctioned under Rule 11.

Lawyer

A magistrate judge found that attorney Tae Sture included two non-existent citations, generated by an AI research tool, in a brief, in violation of Rule 11. The district court adopted the Rule 11 analysis but reduced the monetary sanction to $2,000, payable to the Clerk, while declining to adopt the state-rule findings (separately referred to the Indiana Disciplinary Commission).

Pro Se Litigant

The court observed that plaintiffs' sweeping claims included citations to hallucinated law apparently obtained from generative AI tools, alongside fundamental misunderstandings of Virginia law. The court addressed the claims on the merits; no sanction is reported in the provided text.

Pro Se Litigant

The court affirmed dismissal of the pro se plaintiff's complaint and noted that her briefs were replete with inaccurate citations, which caused the opposing party and the court to expend unnecessary effort to discern her claims. The opinion quoted authority cautioning against reliance on artificial intelligence in brief preparation; no penalty was imposed.

Lawyer · LexisNexis AI

Defense counsel admitted using LexisNexis's AI tool to construct submissions, failing to review the final versions, and acknowledged that certain citations resulted from AI hallucinations and did not support the propositions cited. The court ordered Defense Counsel to pay $1,710 of a $48,690 fee award attributable to her misconduct and imposed a separate $1,000 deterrence penalty payable to the Clerk, for $2,710 in liability tied to the AI conduct; the remaining fee and cost amounts were assigned to the defendants.

Lawyer

The court denied attorney T. Michael Morgan's motion to appear pro hac vice, citing his prior sanction in the District of Wyoming (Wadsworth v. Walmart) where he signed motions in limine citing eight non-existent cases hallucinated by his firm's in-house AI platform. The court was troubled by that demonstrated failure.

Lawyer

In response to an order to show cause, petitioner's counsel admitted that cases cited in his papers were incorrectly cited and did not support his argument, and withdrew the argument. The court found a non-monetary sanction appropriate under Rule 11(b)(4) and publicly admonished counsel on the record.

Lawyer

The magistrate judge ordered plaintiff's counsel to provide PDF copies and pinpoint locations for quotations in his summary-judgment briefing, to explain where any unverifiable cases and quotations originated, and to disclose whether and to what extent generative AI was used in drafting.

Lawyer

The Seventh Circuit observed that the submission of a brief with numerous citations and quotations that do not exist is a serious dereliction of counsel's duty as an officer of the court, regardless of how the errors arose. The court addressed the citation problem in the course of deciding the appeal.

Lawyer

The Appellate Division recounted that respondent, hired to draft a federal show-cause response, produced a draft containing citations to non-existent cases that the underlying federal court attributed to ChatGPT or a similar AI program. In this disciplinary proceeding the court granted the Attorney Grievance Committee's motion and immediately suspended respondent from the practice of law in New York; no monetary sanction was imposed in this order.