Regulayer

The pattern, case by case

The sanctions are real,
and they compound.

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 of nine 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

What every one of these lacked

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.

Generate the certification →

Checked 20 July 2026. Amounts marked as reported rest on the linked coverage rather than the order text. Information, not legal advice.