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 suspension, then the bar referral. Every row below carries its source; where the source is reporting rather than the court's document, the row says so.
As of 17 September 2026: 49 matters, of which 38 were read against the issuing body’s own document and the rest are recorded from reporting, a compilation or a commercial reprint, each row saying which · largest single penalty $110,204.38 (Couvrette v. Wisnovsky, combined against two lawyers) · first suspension: People v. Crabill (Colorado, 2023). Record last verified 17 September 2026.
Volume: in Parnell v. Florida Department of Corrections, 181 F.4th 1209 (11th Cir. 2026), the court described the Charlotin AI Hallucination Cases database as listing over 1,000 judicial decisions dealing with AI hallucinations. That is the court’s own characterisation of a compilation, not a primary source and not a census.
The regulator has now written the warning down in advance: the SRA’s warning notice on the misuse of AI of 17 August 2026 tells every firm and individual it regulates that failing to have proper regard to it risks disciplinary action.
The full record, sortable. Click a column heading to sort; click again to reverse. Case names link to our page on the matter where one exists. Amounts marked as reported rest on the linked coverage rather than the order text.
| Judge / case▲▼ | Court▲▼ | Date▲▼ | AI tool▲▼ | What happened▲▼ | Outcome▲▼ | Source |
|---|---|---|---|---|---|---|
| Mata v. Avianca, Inc.678 F. Supp. 3d 443 (Castel, J.) | S.D.N.Y. | 22 Jun 2023 | ChatGPT | Six nonexistent, ChatGPT-generated cases cited in an opposition brief; when challenged, counsel filed fabricated copies of the opinions. | $5,000 penalty, jointly and severally on two attorneys and the firm; letters to the client and to the judges falsely named as authors. | Opinion and order, Doc 54 (CourtListener) |
| People v. CrabillNo. 23PDJ067 (stipulation) | Colo. O.P.D.J. | 22 Nov 2023 | ChatGPT | ChatGPT citations in a motion to set aside judgment; counsel knew they were fictitious before the hearing, said nothing, and blamed a legal intern. | Suspension of one year and one day, 90 days served, the rest stayed on two years' probation. The first suspension in this record. | Stipulation to discipline (Colo. O.P.D.J. PDF) |
| Wadsworth v. Walmart Inc.348 F.R.D. 489 (Rankin, J.) | D. Wyo. | 24 Feb 2025 | MX2.law, the firm’s in-house platform (as reported) | Eight of nine cases cited in motions in limine did not exist; the citations came from the firm's own AI platform, not a consumer chatbot. 348 F.R.D. 489. | $3,000 and revocation of pro hac vice admission for the drafting attorney; $1,000 each for the supervising partner and local counsel who signed. | Order text (FindLaw mirror) · As reported (LawNext) |
| Lacey v. State Farm Gen. Ins. Co.No. 2:24-cv-05205-FMO-MAA, 2025 WL 1363069 | C.D. Cal. | May 2025 | CoCounsel, Westlaw Precision, Google Gemini (as reported) | As reported: nine of 27 citations in a brief were wrong, some to nonexistent cases, some misstating the law, in work by one firm that the filing firm did not check. | $31,100 in fees and costs, joint and several against two firms. (Amount per the order, cited in Johnson v. Dunn, 792 F. Supp. 3d at 1266.) | As reported (Clearbrief) |
| Coomer v. LindellNo. 1:22-cv-01129-NYW, 2025 WL 1865282 (Wang, J.) | D. Colo. | 7 Jul 2025 | Generative AI (as reported) | A brief with roughly thirty defective or nonexistent citations; counsel said an earlier draft was filed by mistake. | $3,000 against each of two attorneys (one jointly and severally with his firm), payable to the registry. Judge Wang now requires an AI certification with filings. A further $5,000 followed on 7 May 2026 for another nonexistent case. | July 2025 order (PDF) · NPR · 2026 follow-up (Colorado Politics) |
| Johnson v. Dunn792 F. Supp. 3d 1241 (Manasco, J.) | N.D. Ala. | 23 Jul 2025 | ChatGPT | Five fabricated case citations across two discovery motions, filed by three partners at a national firm whose own AI policy required verification. | Public reprimand, disqualification from the case, referral to every licensing authority, order published in the Federal Supplement. No fine: fines, the court wrote, have not deterred the pattern. | Sanctions order (PDF) |
| Couvrette v. WisnovskyNo. 1:21-cv-00157-CL, 2025 WL 4109655 (Clarke, M.J.) | D. Or. | 12 Dec 2025 | Generative AI (unspecified) | Fifteen nonexistent cases and eight fabricated quotations across three summary-judgment briefs; correction by errata still misstated the law. | $110,204.38 combined (sanction of 12 Dec 2025; fee apportionment of 23 Mar 2026, ECF 225): $95,998.72 on lead counsel, $14,205.66 on local counsel. Case dismissed with prejudice; Oregon State Bar notified. | Docket (CourtListener) · Amounts as reported with ECF and WL cites |
| Whiting v. City of AthensNos. 24-5918/5919, 25-5424 (Bush, J.) | U.S. Court of Appeals, 6th Cir. | 13 Mar 2026 | Not established, the attorneys declined to answer the court's AI question | “Over two dozen fake citations and misrepresentations of fact” in the briefs across three consolidated appeals, itemized in an appendix to the opinion. | $15,000 each, payable to the court registry, on two attorneys; joint and several liability for the appellees' reasonable fees; double costs; referral to the chief judge for discipline under Local Rule 46. | Published opinion (6th Cir. PDF) · Same (CourtListener) |
| Fletcher v. ExperianNo. 25-20086, 168 F.4th 231 (Elrod, C.J.) | U.S. Court of Appeals, 5th Cir. | 18 Feb 2026 | Not named; the court found generative AI drafted substantially all of the reply brief | Sixteen fabricated quotations and five misrepresentations in a reply brief; the court found it likely that AI also wrote the show-cause response. | $2,500 payable to the court within 30 days, under FRAP 46(c) and the court’s inherent power. The court said candour would likely have produced a lesser sanction. | Published opinion (5th Cir. PDF) |
| In re NwaubaniNo. 25-9517 (Standing Panel on Attorney Discipline) | U.S. Court of Appeals, 4th Cir. | 11 Mar 2026 | Not established; the attorney denied using generative AI | Three nonexistent cases in an employment discrimination appeal, including a citation to a Supreme Court decision that does not exist. | Public admonishment for violating Fourth Circuit Local Rule 46(g)(1)(c), on a separate disciplinary docket with prosecuting counsel appearing. | Opinion (4th Cir. PDF) |
| United States v. FarrisNo. 25-5623 (per curiam) | U.S. Court of Appeals, 6th Cir. | 3 Apr 2026 | Westlaw CoCounsel, admitted | Court-appointed defence counsel had AI draft both appellate briefs, then filed them unverified. Every case cited was real; three quotations appear nowhere, and two holdings were reversed in the telling. | No Criminal Justice Act compensation for the appeal; removed from the case by separate order, briefs locked, replacement counsel appointed; referred to the Sixth Circuit chief judge, the E.D. Ky. chief judge and clerk, and the Kentucky Bar Association. | Published opinion (6th Cir. PDF) |
| Gamez v. County of FresnoNo. 1:26-cv-00297-KES-EPG (Grosjean, M.J.) | U.S. District Court, E.D. Cal. | 9 Apr 2026 | A paid generative AI tool the attorney believed had anti-hallucination protection | An opposition brief that cited authority that does not exist, fabricated quotations from authority that does, and made material legal representations without support. | No sanction. The show-cause order was discharged on 9 April 2026 after a candid, detailed explanation. We carry it because a record you can trust must hold the cases that cut the other way. | Show-cause order (E.D. Cal. PDF) |
| Fivehouse v. U.S. Dept of DefenseNo. 2:25-CV-00041-M (Numbers, M.J.) | U.S. District Court, E.D.N.C. | 27 Apr 2026 | Not named; generative AI use admitted after the errors were first called clerical | A former Assistant United States Attorney filed a government brief with fabricated quotations and misstated holdings from Fourth Circuit opinions. | Public reprimand under the court’s inherent authority, ordered submitted for publication. Limited only because he had already resigned; the court said courts must move “beyond admonitions and reprimands into more punitive sanctions.” | Order, ECF No. 129 (E.D.N.C. PDF) |
| Ayinde v Haringey[2025] EWHC 1383 (Admin) (Divisional Court) | High Court of Justice, England and Wales | 6 Jun 2025 | Not established in either matter | Two joined matters. Five nonexistent cases in a housing judicial review; eighteen of forty-five citations nonexistent in a commercial claim where the solicitor relied on his lay client’s research. | £2,000 wasted costs against counsel stood; referral to the Bar Standards Board; two separate referrals to the Solicitors Regulation Authority. A paralegal was found blameless. Decided under the Hamid jurisdiction. | Judgment (The National Archives) |
| Zhang v. Chen2024 BCSC 285 (Masuhara J.) | Supreme Court of British Columbia, Canada | 20 Feb 2024 | ChatGPT, admitted | Two fabricated cases in a notice of application for parenting time, and a delay in telling opposing counsel once counsel knew they were fake. | Special costs refused, no reprehensible conduct found. Costs ordered personally against counsel under Family Rule 16-1(30)(c) and (d) for four half-days, plus an order to review every other file before the court and report within 30 days. | Corrected reasons (BC Courts) |
| Ko v. Li2025 ONSC 2766 / 2965 / 6785 (Myers J.) | Ontario Superior Court of Justice, Canada | 4 Dec 2025 | ChatGPT, denied then admitted | Fake citations in a family law factum, relied on in oral argument. Asked in open court if she had used ChatGPT, counsel said “I did not”, then blamed staff and a student, then confessed by letter that she had written it alone using ChatGPT. | First contempt purged May 2025. Then a fresh criminal contempt proceeding, carriage referred to the Attorney General of Ontario, amicus appointed, Law Society investigating. Maximum penalty on summary criminal contempt is imprisonment of less than five years. Live and undecided. | Endorsement, 2025 ONSC 6785 (PDF) |
| Bandla v SRA[2025] EWHC 1167 (Admin) | High Court of Justice, England and Wales | 2025 | Denied; claimed a Google search | 27 authorities listed by the SRA as non-existent in an appeal against strike-off, two of which the judge thought wrongly criticised. He had never checked any of them. | Extension of time refused and grounds of appeal struck out as an abuse of the process of the court. Indemnity costs sought. The sanction was losing the case. | Judgment (The National Archives) |
| Harber v HMRC[2023] UKFTT 1007 (TC), TC09010 | First-tier Tribunal, Tax Chamber, England and Wales | 4 Dec 2023 | AI “such as ChatGPT”, as found | A litigant in person supported a reasonable-excuse argument with nine First-tier Tribunal decisions. None were genuine. | No sanction. The Tribunal found as a fact that she did not know the cases were fabricated and did not know how to check case law. Appeal dismissed on its merits. The earliest UK instance on this record. | Decision (The National Archives) |
| Dayal, and the regulator outcome[2024] FedCFamC2F 1166; VLSB+C variation | Federal Circuit and Family Court of Australia; Victorian Legal Services Board | 19 Aug 2025 | Not named; AI-generated list of authorities | A list and summary of authorities generated using AI, with inaccurate citations and summaries, tendered to the court. Referred to the regulator. | The only published regulator decision anywhere. Practising certificate varied: no longer a principal, no trust money, no own practice, employee solicitor only, two years supervised practice, quarterly reporting by him and his supervisor. | VLSB+C statement, 2 Sept 2025 |
| Hussein v. Canada2025 FC 1060 | Federal Court of Canada | 2025 | Admitted AI use after concealment | Cases that did not exist or were inaccurately cited for the propositions advanced. Counsel admitted relying on AI and failing to verify. | Special costs. The Court found that concealment of his reliance on AI amounted to misleading the court. | Federal Court AI practice notice |
| Mavundla, and Northbound ProcessingKwaZulu-Natal High Court; Gauteng Division | High Court of South Africa | 2025 | Online research tool; “Legal Genius” in the second matter | Only two of nine authorities were genuine. The advocate had not verified and relied on a candidate attorney’s research. A later Gauteng matter involved a paid subscription tool. | Conduct called “irresponsible and unprofessional”; referred to the Legal Practice Council. The first African entry on this record. | Recorded from South African legal commentary; SAFLII was unreachable and neither judgment was read at source |
| Oregon: a published rate cardRingo v. Colquhoun Design Studio, LLC (Lagesen, C.J.) | Oregon Court of Appeals | Dec 2025 | Not named | Two fabricated citations and one fabricated quotation attributed to a real case. | $2,000, itemised: $500 per fabricated citation and $1,000 per fabricated quotation. The first published per-infraction rate anywhere. “A long cut to justice.” | Recorded from contemporaneous reporting; the opinion was not read at source |
| Nebraska: suspended until further noticeSuspension order of the Chief Justice | Nebraska Supreme Court | 16 Apr 2026 | Admitted AI use | A divorce appeal brief in which, as reported, 57 of 63 citations were defective, including entirely fabricated cases. | Suspended from the practice of law until further notice. No fine; the license. | Recorded from contemporaneous reporting; the order was not read at source |
| Sethi and RoundsLNU v. Blanche | U.S. Court of Appeals, 9th Cir. | 2026 | Not named | Non-existent cases, invented quotations and grossly inaccurate descriptions of real law, in immigration briefs. The court had already ruled in the clients’ favour. | $2,500 each; six-month suspension from practice before the Ninth Circuit; and the firm must disclose generative AI use in filings for two years. | Recorded from contemporaneous reporting; the order was not read at source |
| Gonzalez v. Texas TaxpayersW.D. Tex. | U.S. District Court, W.D. Tex. | 2026 | A citation generator, denied then admitted | Defective citations. Counsel first denied using AI, then admitted using a citation generator. | Approximately $4,000 in fees and costs. The cheapest instance of the denied-then-admitted sequence. | Recorded from sanctions surveys; the order was not read at source |
| Barteca Holdings LLC v. Tacobarn Newtown LLC26-CV-250 (VDO) | D. Conn. | 4 Aug 2026 | Open Law, Claude, Chat GPT | “Failed to conduct a reasonable human verification of the authorities cited.” Three tools named; one finding for all three. | $3,500 to the Clerk under Rule 11, plus referral to the Grievance Committee under L.R. 83(c)(2). | Read at the order text, 15 Aug 2026 |
| In re BFI Waste Systems of Tennessee3:22-cv-00605 | M.D. Tenn. | 6 Aug 2026 | Not named; AI powered legal research tools generally | Rule 11 violation. “Publicly reprimanded through this order”: the reprimand is permanent and searchable. | Public reprimand plus $1,500.00 to the Clerk within 30 days. | Read at the order text, 15 Aug 2026 |
| Ali v. Osman2026 ND 156, No. 20260029 | Supreme Court of North Dakota | 6 Aug 2026 | AI-assisted drafting | The court found “multiple fictitious or nonexistent citation errors”. | $1,000 payable to the appellee. | Recorded from the Charlotin database; the order was not read at source |
| Isles v. Family Dollar, Inc.1 CA-CV 25-0918 | Arizona Court of Appeals, Div. One | 6 Aug 2026 | AI-assisted drafting | Citation failures on appeal drew a fee and cost award. | Fees and costs to the appellee under A.R.S. §12-341 and ARCAP 21. The order does not fix an amount. | Recorded from the Charlotin database; the order was not read at source |
| Egan v Commonwealth of Australia[2026] FCA 1104 | Federal Court of Australia | 11 Aug 2026 | AI-assisted drafting | A litigant in person filed a correcting notice and apologised for AI citation errors. | No penalty. The correction and apology were accepted. | Read at the judgment text, 26 Aug 2026 |
| Arbuckle v. Tanner2026 NSCA 62 | Nova Scotia Court of Appeal | 12 Aug 2026 | Several AI tools, compiling the appeal book | Filed transcripts carried a real transcriber’s name, registration number and signature; she had not made or certified them. “Non-compliance well disguised as compliance.” | Appeal dismissed; $20,000 costs on an indemnification basis under Rule 90.40(4). | Read at the decision text, 26 Aug 2026 |
| Faiz Enterprise v. State Tax OfficerR/SCA/10123/2026 | High Court of Gujarat | 20 Aug 2026 | AI-generated case law, relied on by the decision-maker | Not a filer: the decision-maker. A tax officer’s cancellation order relied “exclusively on the AI generated case laws”, one case non-existent. | Orders quashed. Statewide verification instructions incorporated into the court’s order; violation “would amount to contempt”. | Read at the judgment text, 26 Aug 2026 |
| Capital Standard v. U.S. Bank2D2024-1392 | Fla. 2d DCA | 21 Aug 2026 | Not named in the sanction; AI misuse found | Forty-six fabricated or misdescribed citations across two briefs. The show-cause response came over a month late. | $1,500; personal payment of the appellee’s appellate fees (amount remanded); Florida Bar referral; no charge to the clients. | Read at the opinion text, 26 Aug 2026 |
| Sheppard v Jillion LLC[2025] QIC (E) 3 | QFC Civil and Commercial Court, Qatar | 12 Nov 2025 | Not named; the cases came from a Google search | Two decisions of this Court cited in an application for an extension of time; neither exists. The self-represented claimant noticed at 06:01 the next morning. Three shifting accounts followed. | Contempt of court and breach of article 35.2 proved, and no penal sanction imposed. The lawyer was anonymised and is not named here. A draft of the court’s AI practice direction was published the same day. | Read at the sealed judgment, 27 Aug 2026 |
| Shelbert v. Baxter InternationalNo. 26 C 6266 | N.D. Ill. | 26 Aug 2026 | Not named in the order; AI authorship inferred from filing times | A motion to strike filed 1 hour 25 minutes after a twenty six page Answer, bespoke rather than boilerplate. A Seventh Circuit decision cited for a proposition it does not contain. | Rule 11 notice and admonishment to both parties, no monetary sanction. The court held the result would be the same with or without AI. | Read at the order text, 30 Aug 2026 |
| James v. Conley1:23-cv-24467 | S.D. Fla. | 27 Aug 2026 | Not named; AI-generated content conceded by counsel | An AI-generated police training document alleged to exist and pleaded as the basis of allegations. Not a fabricated case: a fabricated fact. The position was held for months after notice. | Recommendation only, nothing imposed. Rule 11 motion recommended denied on a threshold procedural ground, the movant having failed the Rule 11(c)(2) safe harbor. Separately and sua sponte, four counsel recommended for referral to the district’s grievance committee. Fourteen days to object. | Read at the Report and Recommendation, 30 Aug 2026 |
| Ruiz v. Magellan FinancialCV-23-02090-PHX-DWL | D. Ariz. | 24 Aug 2026 | ChatGPT, named in counsel’s own response | Two false quotations triggered a show-cause order. The court then found three more briefs itself. Three with fabricated quotations, a fourth with an inaccurate case summary. | Formal public reprimand under the ABA Standards ladder, and a duty to report the discipline. No monetary penalty. Conduct found at least negligent, arguably reckless, not knowingly deceptive. | Read at the order text, 30 Aug 2026 |
| Benjamin v. State2026 WL 2491126 | App. Ct. Md. | 25 Aug 2026 | Not admitted; the court said AI use “seems likely” | Multiple inaccurate citations in an appellant’s brief. Errata filed, then a motion to correct and a motion to strike, both denied. No admission of AI use. | Referral to the Attorney Grievance Commission expressly declined, with reasons: the brief predated Mezu, the errors were not excessive and included no wholly invented cases, correction was attempted, and no harm was asserted. | Read at the opinion text in a commercial reprint, 30 Aug 2026; unreported |
| Parnell v. Florida Dept of Corrections181 F.4th 1209 | 11th Cir. (published) | 10 Jul 2026 | Not named; the opinion refers to a generative AI platform as one possibility | Two non-existent opinions and at least five non-existent quotations from the Eleventh Circuit’s own decisions in a reply brief. Counsel withdrew them and argued the motion was moot. | Merits affirmed; portions of the reply brief struck; fees granted for the motion to strike with the amount reserved; counsel referred to the Committee on Lawyer Qualifications and Conduct. | Read at the published opinion, 30 Aug 2026 |
| State of Hawaiʻi v. PrestiNo. CAAP-24-0000826 | ICA Hawaiʻi (published) | 31 Aug 2026 | Not named; the opinion cites the AI Hallucination Cases database | An opening brief cited 95 authorities; the court could reliably identify 41, and eleven could not be located or were demonstrably wrong. The State did not raise it; the court found it itself. | Civil Rule 11 not extended to a direct criminal appeal, on constitutional grounds; but each citation to nonexistent authority is a basis for sanction under HRAP Rules 30 and 51. No sanction imposed; affirmed. | Read at the published opinion, 1 Sept 2026 |
| Booker v. The Kroger Co.No. 1:26-cv-02006-SDG | N.D. Ga. | 28 Aug 2026 | Not named; counsel denied AI use in open court, then acknowledged consulting AI tools | Four fake, false and misleading authorities. Asked in open court whether he had used AI, counsel said he had not; his show-cause response acknowledged he had “consulted” AI tools. The court found he “repeatedly, has lied to the Court”. | $1,000 per authority, doubled for the lies: $8,000 to the registry within 30 days. Fee award to the defendant declined. Documentation of the claimed ethics and technology CLE ordered within 7 days; further sanctions reserved. | Read at the order, 1 Sept 2026 |
| Kiser v. DeSimone Auto GroupNo. 2428 EDA 2025 | Pa. Super. (non-precedential) | 27 Aug 2026 | Not named; the court declined to say what produced the citation | A brief cited “Com v. Reid, 770 A.2d 771 (Pa. Super. 2001)”. The court “can find no such case in existence”; that citation leads to Commonwealth v. Burton, which addresses neither Pa.R.E. 404(B)(2) nor res gestae. | No sanction. The issue was waived as underdeveloped and “supported in part by non-existent or unlocatable precedent”; a further issue waived; judgment affirmed. | Read at the memorandum, 1 Sept 2026 |
| Gadiya v. Union of India2026 INSC 947 | Supreme Court of India | 2 Sep 2026 | AI-generated case law, relied on by the decision-maker | Not a filer: the decision-maker. A customs officer’s penalty order relied on case law “either non-existent or [with] fake citations”, and on real cases that did not lay down what the order said they did. | Penalty of Rs 425,27,99,100 set aside together with the High Court order upholding it; remitted to a different officer of the same rank. No materiality inquiry: under the Court’s own rule, such a decision is “no decision in the eyes of the law”. | Read at the order text, 3 Sept 2026 |
| Scott v. Illinois Human Rights Commission2026 IL App (1st) 251462 | Ill. App. (1st), published | 28 Jul 2026 | ChatGPT, a “premier corporate subscription”, named in counsel’s own response | Ten false citations across two briefs: four false statutory quotations, one nonexistent case and five real cases that do not say what was claimed. The court-ordered explanation “itself contains misstatements of law”. | $1,500 per false citation, $15,000 to the clerk within 30 days, a rate set above past practice because existing fines “are not enough to deter improper AI use”. Opinion sent to the ARDC. Service on every judge and CLE considered, declined for want of authority under Rule 375, and “strongly encourage[d]”. | Read at the published opinion, 7 Sept 2026 |
| Mazaheri v Law Society of Ontario2026 ONLSTH 112 | LST (Ont.) | 12 Jun 2026 | Grok, named by the licensee in his own letter | A suspended licensee, self-represented, filed a factum, supplementary factum, affidavit and supplementary affidavit produced with generative AI, citing tribunal decisions that do not exist. The first time, as far as the tribunal knew, that invented authorities were put before it. | $31,150 in costs to the Law Society on two failed motions. The tribunal would have awarded most of those costs anyway; the irresponsible use of AI was “an additional and significantly aggravating factor” that took the award to full costs. Not an AI fine. No determination of professional misconduct in this decision. | Read at the Tribunal’s own decision, 17 Sept 2026 |
| Solicitors Regulation Authority v KumarCase No. 12884-2026 | SDT (E&W) | 25 Aug 2026 | Generative AI, not named anywhere in the judgment | A written Answer to the regulator containing misleading quotations and citations produced with generative AI, then an email admitting the use which itself contained further erroneous citations. A Registered Foreign Lawyer, not a solicitor. | Struck off the Register of Foreign Lawyers, no order as to costs. Two allegations, both proved, and the Tribunal recorded it would have imposed the same sanction on either standing alone. It found two separate failures: to ensure the output was accurate, and to satisfy himself the tools were reliable. | Read at the Tribunal’s own judgment, 11 Sept 2026 |
| State ex rel. Schnell v. RichardsonNo. ED114731 | Mo. App. (E.D.) | 8 Sep 2026 | Generative AI, not named, admitted in counsel’s response | Two cited cases that counsel “now admits do not exist”: cases bearing those names exist, but not at the citations given and not for the proposition. The court acted on them and ordered suggestions in opposition. | $1,750 to the petitioners as reasonable attorney’s fees, Rule 55.03(c). “This Court is not sanctioning Conley because she used generative AI”; the sanction is for filing cases that do not exist, “no different than if Conley signed her name to work prepared by someone else without verifying”. No referral; conduct rules left to the Supreme Court of Missouri. | Read at the opinion, 9 Sept 2026 |
| State v. Coleman2026-Ohio-965, 280 N.E.3d 1042 | Ohio App. (11th Dist.) | 20 Mar 2026 | ChatGPT, named in the decision | Fabricated trial transcript quotations, not case law, attributed to the prosecutor in an application to reopen a criminal appeal; prepared by a paralegal from ChatGPT output, filed under counsel’s affidavit, unverified, and not withdrawn after the State identified them. | Eight sanctions. $2,000; referral to the Office of Disciplinary Counsel; service of the judgment on every court entered for two years; a signed verification certification on every Ohio filing for two years covering citations, quotations, factual representations, AI disclosure and personal review; six hours of CLE; the filing struck; removal as counsel; written apologies. Contempt for non-compliance. One judge dissented from all but the fine and the referral. | Read at the court’s decision, 9 Sept 2026 |
| Asiedu v. EastlundNos. A25-2106, A26-0532 | Minn. App., nonprecedential | 8 Sep 2026 | AI research tool, not named, admitted at the hearing | Self-represented. Case law cited “either misleading, false, [or] non-existent”; admitted using AI as a research tool and not checking the citations because he was “doing this part time”. | $2,341.25, the respondents’ reasonable costs and attorney fees, under the district court’s inherent authority; affirmed. “We hold pro se parties to the same standard as attorneys when filing documents in court.” | Read at the opinion, 9 Sept 2026 |
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 → · The judges' AI orders, one page each →
Scope note. This record tracks matters in which a court or disciplinary body sanctioned a lawyer over fabricated or defective citations linked to AI use, verified against the court's own document or contemporaneous reporting; it is a curated set, not a census. Damien Charlotin's AI Hallucination Cases database tracks the larger universe. Checked 30 August 2026. Amounts marked as reported rest on the linked coverage rather than the order text.
The other half of the problem
Every matter on this page is an attorney citing an authority that does not exist. The harder question is what happens when the evidence is what a machine made. That record is kept separately: when the evidence itself is made by AI, opened with the Derbyshire investigation and the PoliceAI pause on generative AI in court statements.
Information, not legal advice. Every entry is verified against the court's own document or contemporaneous reporting; where a source is reporting rather than the document, we say so.
The same failure, in other courts
Most of these are United States matters, and the record already reaches past them: Ayinde v Haringey in England and Wales, Zhang v Chen in British Columbia, Mavundla in South Africa. Courts elsewhere are deciding the same question, and twenty-eight entries across twenty-four jurisdictions now publish rules meant to prevent it happening again.
AI rules for lawyers, country by country →