Live tracker
When AI citations
reach the lawyer.
A running record of US court matters involving AI-generated citations that could not be verified, by lawyers and other represented parties, from warnings and show-cause orders to fines, suspensions, and bar referrals. Every row links to the underlying court document. We maintain it because the risk Veritas addresses is documented, public, and growing fast.
384
US attorney matters tracked
$555,531+
in monetary penalties imposed
132
with professional sanctions (suspension, bar referral, more)
Since 2023
and accelerating
384 of 384
| Case | Court | Date | Outcome |
|---|---|---|---|
| Scott v. Illinois Human Rights Comm'n 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. | CA Illinois (1d) | Jul 28, 2026 | Monetary penalty: $15,000 payable to the clerk of the Appellate Court, First District, within 30 days; opinion forwarded to the Illinois Attorney Registration and Disciplinary Commission FineBar referralProfessional sanction |
| In re A.P. 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. | Ohio CA (12th) | Jul 27, 2026 | No penalty imposed; parties reminded that citations the court cannot verify may result in sanctions Warning |
| Lichfield v. Kubler 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. | CA Tenth Circuit | Jul 27, 2026 | No sanction imposed; brief held non-compliant with 10th Cir. R. 46.5 and counsel cautioned Warning |
| Rose Lannquist Gouldy v. Timothy Michael Chiasson 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. | CA Florida (4th) | Jul 22, 2026 | Affirmed in all respects; separate order to show cause why appellant should not be barred from further pro se filings Show causeAlleged |
| Chryshawna A Webb v. Sullivan County Assessor 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. | Indiana Tax Court | Jul 16, 2026 | Admonishment; no further penalties imposed Warning |
| dineen/shibata v. Kotchka 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. | CA Arizona | Jul 15, 2026 | Sanction: the portion of appellee's reasonable attorney fees attributable to the unverified citations, plus costs on appeal (amounts contingent on ARCAP 21 compliance) FineShow cause |
| Del Biaggio v. Bansen 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. | CA California | Jul 10, 2026 | Monetary penalty: $1,500 payable to the clerk of the court within 30 days of remittitur; opinion forwarded to the State Bar of California; client notice and certification required FineBar referralProfessional sanction |
| Estate of Lane Caviness v. Atlas Air, Inc. 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. | CA Eleventh Circuit | Jul 10, 2026 | Dismissal affirmed; matter referred by the Chief Judge to the Committee on Lawyer Qualifications and Conduct in a separate order Bar referralProfessional sanction |
| Marion Parnell, Jr. v. Florida Department of Corrections 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. | CA Eleventh Circuit | Jul 10, 2026 | Motion to strike granted; attorney's fees for the motion granted with the amount reserved; counsel referred to the Committee on Lawyer Qualifications and Conduct FineBar referralProfessional sanction |
| Kevin Leiske v. Robert Gregory Kidd 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. | Delaware C. Ch. | Jul 1, 2026 | Rule to show cause issued to the signing attorney and his firm under Rule 11(c); affidavits ordered by July 15, 2026 Show cause |
| Morgan v. Jones 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. | Ohio CA (1st) | Jun 26, 2026 | AI-citation sanction denied as a matter of warning; vexatious-litigator motion also denied. Warning |
| Landberg v City of New York 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. | App. NY (2d) | Jun 24, 2026 | Monetary penalty: $8,000 (attorney) and $2,500 (firm), payable to the Lawyers' Fund for Client Protection of the State of New York Fine |
| Barber v. Morawa 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. | CA Michigan | Jun 17, 2026 | Sanction ordered against plaintiff's counsel personally; actual damages and reasonable attorney fees to be determined on remand. Fine |
| Holstein v. Holstein 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. | Ct. App. Indiana | Jun 16, 2026 | Sanction request (appellee sought $5,000 in attorney's fees) denied; monetary sanctions not warranted. Warning |
| Jacob Doe v. The University of North Carolina System 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. | W.D. North Carolina | Jun 16, 2026 | Order to show cause discharged without sanction. |
| Quinteros v. Harbor Distributing 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. | Ct. App. Cal., 1st Dist. | Jun 11, 2026 | Monetary penalty: $6,000 jointly and severally ($5,000 payable to defendants, $1,000 payable to the court); affirmed on appeal. Fine |
| Shani Washington v. Jermel Washington 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. | CA Georgia | Jun 4, 2026 | Caution issued (no penalty imposed) Warning |
| Euphoric, LLC et al. v. Westport Community Improvement District, et al. 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. | W.D. Missouri | Jun 3, 2026 | Admonishment (no penalty imposed) Warning |
| Lnu v. Blanche 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. | 9th Cir. | Jun 3, 2026 | Monetary penalty: $2,500 per attorney; 6-month suspension from the court; State Bar referral FineSuspensionProfessional sanctionBar referral |
| Wayne K. Smith, Sr. v. Polk County, et al. 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. | W.D. North Carolina | Jun 3, 2026 | Order to show cause Show cause |
| Fadi El Bitar v. Julio Hernandez 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. | W.D. Washington | Jun 2, 2026 | Monetary penalty: $1,000; public reprimand FineWarning |
| Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, et al. 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. | W.D. Tennessee | Jun 2, 2026 | Rule 11 sanctions: cost/fee reimbursement (amount to be determined); referral to Tennessee Board of Professional Responsibility Professional sanctionBar referral |
| Heriberto Perez-Castillo v. Todd W. Blanche 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. | 7th Cir. | Jun 1, 2026 | Monetary penalty: $5,000; referral of co-counsel to Illinois ARDC FineProfessional sanctionBar referral |
| Garcia v. City of Monte Vista, Colorado et al 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. | D. Colorado | May 29, 2026 | Order to show cause Show cause |
| Boyle, et al. v. Steven Kramer 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. | E.D. Michigan | May 28, 2026 | Warning (objections overruled) Warning |
| In re M.H., M.L., and M.H., Minors 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. | CA Illinois (1d) | May 28, 2026 | No penalty reported (arguments treated as forfeited) |
| Eclectic Synergy, LLC v. Seredin 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. | CA Florida (4d) | May 27, 2026 | Counsel referred to The Florida Bar for appropriate action after the court found a violation of the duty of competence; no monetary sanction. Show causeBar referralProfessional sanction |
| Innocent v. Meraki Installers, LLC Lawyer In this Florida Fourth District appeal, the court addressed counsel's filing containing improper citations and referred the matter for disciplinary review. | CA Florida (4d) | May 27, 2026 | Bar referral Bar referral |
| Robert Hinton Avery W v. Danielle Beauzil 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. | CA Florida (4th) | May 27, 2026 | Pro se filing bar imposed after order to show cause Show cause |
| State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves 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. | SC Oklahoma | May 27, 2026 | Public reprimand (reciprocal discipline) Professional sanctionWarning |
| Williamson v. Meyers (derivatively on behalf of Equinix, Inc.) 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. | D. Delaware | May 27, 2026 | Warning (fabricated authority disregarded) Warning |
| Guo v. Meade Motorcars, L.L.C. 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. | Ohio CA (6th) | May 26, 2026 | Trial-court sanction affirmed on appeal; appeal costs taxed |
| Johnny Fuselier v. John S. Riscassi 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. | S.D. Mississippi | May 22, 2026 | Order to show cause Show cause |
| Kings Roofing Nwfl, LLC v. Fusion Works Construction, LLC 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. | CA Florida (1st) | May 22, 2026 | Order to show cause on sanctions and possible Florida Bar referral Show cause |
| Kings Roofing v. Fusion Works 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. | CA Florida (6th) | May 22, 2026 | Appeal dismissed; order to show cause; bar referral Show causeBar referral |
| Dalton Gage Hill v. Oklahoma County Criminal Justice Authority (2) 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. | W.D. Oklajoma | May 21, 2026 | Report and Recommendation: Rule 11 sanctions (attorney fees, amount to be determined) and contempt recommended FineProfessional sanction |
| In re the Marriage of Amy Haddock and Justin Blu Haddock 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. | Tulsa County DC | May 21, 2026 | Monetary sanction: $2,000; Oklahoma Bar Association notified FineProfessional sanctionBar referral |
| Jackie L. Miller v. Regions Bank 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. | N.D. Alabama | May 21, 2026 | Disqualification from case; suspension from N.D. Ala.; bar referral DisqualificationSuspensionProfessional sanctionBar referral |
| Shaker Hts. v. Thompson 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. | Ohio CA (8th) | May 21, 2026 | Citations disregarded (no penalty imposed) Warning |
| That Xiong v. Minga Wofford (2) 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. | E.D. California | May 21, 2026 | No sanctions imposed; order to show cause discharged |
| Twigg v. BSN Sports, Inc., et al. 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. | M.D. Pennsylvania | May 21, 2026 | Order to show cause Show cause |
| Davis v. Marion County Juvenile Detention Center 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). | S.D. Indiana | May 20, 2026 | Monetary penalty: $2,000 FineProfessional sanction |
| Sherwood v. County of Botetourt, Virginia, et al. 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. | W.D. Virginia | May 20, 2026 | No penalty reported (claims dismissed) |
| Taffether Hopson v. Capital One Auto Finance, Division of Capital One, N.A. 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. | CA Georgia | May 20, 2026 | Criticism noted in opinion (no penalty imposed) Warning |
| Chakma v. Sushi Katsuei, Inc. 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. | S.D. New York | May 19, 2026 | Monetary penalty: $1,000; plus $1,710 fee reimbursement attributable to counsel FineProfessional sanction |
| Glenn Wilder and Others v. President & Fellows of Harvard College and Others 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. | SC Massachussetts | May 18, 2026 | Pro hac vice admission denied Professional sanction |
| Waggeh v. Utility Workers Union of America Local 1-2 et al. 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. | S.D. New York | May 16, 2026 | Public admonishment (non-monetary Rule 11 sanction) Professional sanctionWarning |
| K.W. v. Ringwood Board of Education 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. | D. New Jersey | May 15, 2026 | Order to explain prior citations Show cause |
| Nikko D’Ambrosio v. Meta Platforms Inc. 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. | CA 7th Cir. | May 15, 2026 | Order to show cause Show cause |
| In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law 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. | App. Div. 1st Dept (NY) | May 14, 2026 | Interim suspension from the practice of law in New York SuspensionProfessional sanctionBar referral |
| Stringer v. White Cap Supply Holdings, LLC Lawyer The court found that plaintiff's response repeatedly cited facts and legal theories with no basis in the record, appeared to potentially violate Rule 11, and raised concerns that the filing may have been the product of impermissible use of AI programs. The court stated it would issue a separate order to show cause to plaintiff's counsel. | M.D. Florida | May 14, 2026 | Order to show cause Show cause |
| Gleason v. Marcus, Canvassing Board of Pinellas County Pro Se Litigant The court addressed authority in the pro se filer's papers that it could not credit, describing unverified reliance of that kind as unwise, unacceptable, and sanctionable, and surveying recent decisions sanctioning similar conduct. It notified him that future filings of this nature would not receive favorable treatment and reminded all litigants, pro se and represented, of the duty to ensure the accuracy of their filings. | CA Florida (2d) | May 13, 2026 | Notice that future similar filings will not receive favorable treatment Warning |
| Jane Doe 1, et al. v. Mount Saint Mary High School Corporation Lawyer The court found that plaintiffs' counsel relied on unverified generative-AI research producing citations that do not exist as written, and that counsel alerted opposing counsel but not the court and did not withdraw the brief. The court fashioned a deterrence-focused sanction; old data indicates a public reprimand with client notice and bar self-referral. | W.D. Oklahoma | May 13, 2026 | Public reprimand; notice to client; self-referral to bar Professional sanctionWarningBar referral |
| Joseph Guy v. AFGE Lawyer The court found that counsel's motion contained quotations that do not exist and that, when questioned at the hearing, counsel was unaware of and could not explain the hallucinated quotations. The court denied the motion to quash and ordered counsel to file a declaration under penalty of perjury explaining the quotations at issue. | N.D. California | May 13, 2026 | Order to explain fabricated quotations Show cause |
| Henri Giovani Morales Jimenez v. Christopher Shanahan Lawyer In denying the habeas petition, the court criticized petitioner's counsel for relying on an abrogated Supreme Court case and at least one nonexistent case, providing case names without citations, and otherwise serving the client poorly. No formal monetary sanction is reported in the provided text. | E.D. New York | May 12, 2026 | Admonishment (criticism of counsel); petition denied Warning |
| Jacobs v. Timberlake Lawyer The appellate court and the respondent were unable to locate or verify a case (Harvey v. Harvey) cited by the relator, and the relator's supplemental brief removed the citation without explanation. The court ordered counsel Camille Patti to show cause why she should not be held in contempt and to address the source of the citation. | CA Louisiana (5d) | May 12, 2026 | Order to show cause (possible contempt) Show cause |
| DeVore v. McCombie Lawyer In granting the defendant's motion to dismiss, the court noted with concern that defendant appeared to cite a case (Beecham v. City of Anniston) that the court was unable to locate, while another cited case was real. The court flagged the apparent non-existent citation but reported no sanction in the provided text. | N.D. Illinois | May 11, 2026 | No penalty reported (concern noted); motion to dismiss granted |
| William Louis Armstrong, III v. City of Milwaukee Lawyer The court noted that the County's reply brief had included a citation to a case that does not exist, but that the County caught and corrected the error the same day, so allowing the correction caused no prejudice. The court granted leave to file the corrected reply and granted judgment on the pleadings; the pro se plaintiff was separately admonished about non-compliant filings. | E.D. Wisconsin | May 11, 2026 | Motion to file corrected reply granted; no prejudice found |
| Kristina Crist v. Roy Chris West, et al. Lawyer Following a show-cause order, the court found that plaintiff's counsel, Rachel Bussett, included nonexistent or misleading case citations in a response brief in violation of Rule 11. The court ordered her to pay $250 to the Clerk for the general court fund. | W.D. Oklahoma | May 7, 2026 | Public reprimand; notice to client; monetary penalty: $250 FineWarningProfessional sanction |
| Song Dow Lee, et al. v. HSBC Bank USA, National Association, et al. Lawyer The court found that plaintiffs' opposition misrepresented the holdings of several cases and included a quotation that does not exist. The court ordered counsel to show cause why it should not impose sanctions of $2,500 and/or dismiss the action; no sanction had yet been imposed. | C.D. California | May 7, 2026 | Order to show cause re: sanctions of $2,500 and/or dismissal Show cause |
Updated through 2026-09-05, refreshed monthly. Compiled from publicly filed US court records involving represented parties (non-pro-se); every row links to the underlying court document. It is not legal advice and it is not exhaustive. If you know of a matter we are missing, tell us at andrew@veritaslaw.app.
None of these had to happen.
Every matter on this page traces to a citation no one verified before filing. Veritas verifies every citation and proposition and produces a hashed, time-stamped record that the work was checked.