The pattern, case by case
A fine, then the fee award, then the pro hac vice revocation, then the bar referral. Every case below is sourced; the reported amounts are labeled as reported.
Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)
The foundational case. Two lawyers and their firm were fined $5,000 jointly after citing six nonexistent, ChatGPT-generated cases. The citation is quoted in federal standing orders to this day. Source
Wadsworth v. Walmart Inc., No. 2:23-cv-118 (D. Wyo., Feb. 2025)
As reported: a $3,000 fine and revocation of pro hac vice admission for one attorney, and $1,000 each for two more, after eight cited cases, produced by the firm's in-house AI, did not exist. Source
Lacey v. State Farm Gen. Ins. Co., No. 2:24-cv-05205 (C.D. Cal., May 2025)
As reported: $31,100 joint and several against two firms after roughly nine of 27 citations in a brief were wrong, two to nonexistent cases. The tools involved were mainstream legal AI products. Source
Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025)
As reported: public reprimand of three attorneys, disqualification from the case, and referral to the state bar over fabricated citations. The sanction that outlasts any fine is the referral. Source
Coomer v. Lindell, No. 1:22-cv-01129 (D. Colo., 2025)
As reported: $3,000 against each of two attorneys over a filing with roughly thirty defective or nonexistent citations. The judge who imposed it now requires an AI certification with every filing in her court. Source
A record, made before the question was asked, of what the human actually checked. The attorney's receipt is that record: which AI tools were used, what you personally verified, who signs, sealed at the moment of filing, and verifiable free by the judge who is deciding whether to believe you.
Seven days free, then $349 a month.
A signed record of which AI you used and what you checked, sealed to the exact file you deliver, made on your own machine and checkable free by anyone you send it to.
Each amount re-read against the court’s own order on 30 July 2026. Lacey is a fee-shifting award ordered by a special master rather than a fine, and the page says so. Where a figure rests on reporting rather than on the order text, it is marked as reported. Information, not legal advice.