Was United States v. Farris sanctioned over AI-generated citations?

United States v. Farris (CA 6th Cir., April 3, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Counsel denied CJA compensation for the appeal; referral for disciplinary proceedings. No monetary penalty in this order.

Which AI tool was involved in United States v. Farris?

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

April 3, 2026 · AI sanctions database

United States v. Farris

United States v. Farris 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 6th Cir.
Date: April 3, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Counsel denied CJA compensation for the appeal; referral for disciplinary proceedings
Penalty: No monetary penalty in this order.

DisqualificationBar referralProfessional sanction

What the record shows

The Sixth Circuit found that appointed counsel Steven N. Howe admitted using AI (an unnamed staff member uploaded documents to Westlaw's CoCounsel to create a first draft) and filed briefs without verifying the cited authorities; the court found this resulted in quotations that do not appear in the cited sources and misrepresented holdings, and noted that citing real authorities did not absolve him. The court ordered that Howe not be compensated under the Criminal Justice Act for his time on the appeal and forwarded the opinion for possible disciplinary proceedings.

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 ↗

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 6th Cir.

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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