The sanctions record · Northern District of Georgia, 2026
Booker v. The Kroger Co.
Booker v. The Kroger Co., No. 1:26-cv-02006-SDG (N.D. Ga., Atlanta Division), ECF 66, “Opinion and Order of Sanctions” · Judge Steven D. Grimberg, 28 August 2026
Page verified 1 September 2026. Court document read in full, 6 pages; quotations are from that order. Container: AI Hallucination Cases tracker copy of the court’s document; not downloaded from the court’s website.
Four fabricated case authorities cost plaintiff’s counsel $1,000 each. The court then doubled the total to $8,000, not because of the citations, but because he was asked in open court whether he had used AI tools and said he had not, then acknowledged in writing that he had. Rather than order more training, the court demanded documentary proof of the ethics and technology course he said he had already taken, and reserved the question of further sanctions until it sees it.
The record
- CourtN.D. Ga., Atlanta Division
- JudgeSteven D. Grimberg
- CaseNo. 1:26-cv-02006-SDG, ECF 66
- Order28 August 2026, “Opinion and Order of Sanctions”
- Defective authoritiesFour, described by the court as fake, false and misleading
- Base penalty$1,000 per authority
- MultiplierDoubled, for the false statements about AI use
- Total$8,000, to the court registry’s general sanctions fund within 30 days, with a docket notation on receipt
- FeesFee award to the defendant declined
- Also orderedDocumentation, within 7 days, verifying the ethics and technology CLE counsel claimed to have completed between 26 June and 11 August 2026
- ReservedThe question of additional sanctions, pending that documentation
What the court found
Counsel was asked in open court whether he had used AI tools. The order reproduces the transcript. He answered: “I did not use artificial intelligence.” In his later response to the order to show cause, he acknowledged that he had “consulted” AI tools in drafting the filings.
The court found that he “repeatedly, has lied to the Court”: about the citations, about his AI use at the hearing, and again by “feigning a lack of understanding of the Court’s very straightforward questions about his AI use”.
The doubling is the part worth reading twice. The fabricated authorities were priced at a flat rate. The denial doubled the bill.
The court declined to award the defendant its fees, reasoning that parsing which fees were attributable to the fabricated citations would be cumbersome, and that a court fine is “in line with other sanction orders from this district and this circuit”, serving both as a deterrent and as a partial remedy for the taxpayer resources the court expended.
The order quotes the judge’s own standing order:
“You can use whatever AI tools you like, but only human beings will be held responsible for the outcome.”
Why it matters
This record contains many matters about citations that do not exist. Booker is useful because it separates the failures and prices them separately.
Using an AI tool was not what the court punished. The standing order it quotes says so directly. What drew the penalty was material that had not been checked, and then an account of how the work was done that did not match how it was done.
The last part is the one that should hold a practitioner’s attention. The court did not accept the claim of training at face value. It asked for the documentation, named the window, and kept the file open until it arrives. An assertion about one’s own conduct was treated as something to be evidenced.
The lesson for the next filing
Two questions were asked here. What did you check, and what did you use. Both were answered from memory, months later, under pressure, and the second answer is what doubled the penalty.
A record made at the time of filing answers both without anyone having to be believed: which tools were used, what a named person verified, and who signs. That record is verifiable by the court for free, which is the point of making it before the question is asked.
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Sources
- Booker v. The Kroger Co., No. 1:26-cv-02006-SDG (N.D. Ga.), ECF 66, Opinion and Order of Sanctions, 28 August 2026. Court document read in full, 6 pages. Container: the copy held by the AI Hallucination Cases database, not downloaded from the court’s website.
- United States District Court for the Northern District of Georgia, where the docket itself is held
Related
- The full sanctions record
- Ruiz v. Magellan Financial, where counsel named the tool
- Wadsworth v. Walmart
- The judges’ AI orders, one page each
Verified 1 September 2026 against the court’s written order, read in full. Information, not legal advice.
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.