Was Lichfield v. Kubler sanctioned over AI-generated citations?

Lichfield v. Kubler (CA Tenth Circuit, July 27, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: No sanction imposed; brief held non-compliant with 10th Cir. R. 46.5 and counsel cautioned. No monetary penalty in this order.

Which AI tool was involved in Lichfield v. Kubler?

The order in Lichfield v. Kubler does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

July 27, 2026 · AI sanctions database

Lichfield v. Kubler

Lichfield v. Kubler is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: CA Tenth Circuit
Date: July 27, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: No sanction imposed; brief held non-compliant with 10th Cir. R. 46.5 and counsel cautioned
Penalty: No monetary penalty in this order.

Warning

What the record shows

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.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗ · CourtListener record ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · CA Tenth Circuit

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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