The mistake, and then the worse mistake

Filing citations a chatbot invented is, at this point, a well-documented way to get fined. Courts have a rough rate card for it: a few hundred to a few thousand dollars per fake case, a reprimand, maybe a bar referral if the judge is annoyed. What runs up the bill is not the hallucination. It is what the lawyer does next.

Joshua Watkins, of Burrill Watkins LLC, managed to do nearly everything a lawyer can do wrong after getting caught. In Rivera v. Triad Properties Corp., in the U.S. District Court for the Northern District of Alabama, Judge Anna Manasco sanctioned Watkins and his firm $47,056.90, jointly and severally, which is one of the larger single-attorney AI sanctions on record. The number is that high because the underlying fabrications were only the opening act.

What he filed

Watkins used a generative AI tool to research his filings, and the tool did what these tools do under pressure: it produced citations to cases that do not exist and quotations that appear in no real opinion. That part is familiar. It describes a couple dozen sanctions already catalogued here.

The court's account of what happened after the fake citations surfaced is where the case earns its place. According to Judge Manasco, Watkins "intentionally misled the court" - not once, but repeatedly, across multiple filings and hearings. When the problem came to light, he did not file a clean correction and take his lumps. He submitted corrective filings that continued to mislead, buried the real scope of the misconduct inside what the court described as "convoluted footnotes," and falsely claimed he had informed his own clients about what had gone wrong. Asked direct questions by the court, he changed his answers. The judge's summary is blunt: he "feigned contrition, obfuscated the truth, changed his stories," and pointed the finger elsewhere.

Why the number got so big

Sanctions for AI fabrications are usually calibrated to the fabrications. Count the fake cases, count the fake quotes, attach a dollar figure, done. The Alabama order is larger because the court was not only punishing the hallucinated citations; it was punishing a sustained effort to hide them.

The $47,056.90 was split between the two sets of defendants who had to deal with the mess: $11,453 to the Triad defendants and $35,603.90 to the Fite defendants, payable by Watkins and his firm together. Those figures track the cost of forcing opposing parties to untangle a moving target - to brief, argue, and re-argue against filings that kept shifting as Watkins revised his story. When a lawyer makes the other side spend tens of thousands of dollars chasing the truth, courts can and do make him pay it back.

The parts that outlast the money

The financial penalty is the headline, but the non-monetary consequences are arguably heavier for a working attorney. Judge Manasco publicly reprimanded both Watkins and the firm, disqualified them from further participation in the case, and referred the matter to the Alabama State Bar and other licensing authorities. A bar referral is the kind of thing that follows a lawyer around; it is a separate proceeding with its own potential for suspension or worse.

Then there is the disclosure order, which is the quietly brutal part. Watkins was directed to distribute the sanctions order to all of his clients, to opposing counsel, and to the judges in his other pending cases. That is a court compelling a lawyer to hand every current client and every judge he appears before a document explaining, in a federal judge's words, that he fabricated authority and then lied about it. No fine does that kind of reputational damage. It converts a single ruling into a standing disclosure obligation that touches his entire active practice.

The candor problem, restated

What makes this case a useful cautionary tale is not the hallucination, which by now is ordinary, but the demonstration that the cover-up is what draws the real punishment. The initial fabrications were a competence failure - the kind of thing a contrite lawyer can often survive with a modest fine and a promise to verify next time. Courts have shown considerable patience with attorneys who own the mistake quickly and completely.

They show none for attorneys who try to manage the fallout by misleading the court further. Every distinct misrepresentation - the misleading corrective filing, the convoluted footnotes, the false claim about notifying clients, the shifting answers - was a fresh breach of the duty of candor, and each one gave the court another reason to escalate. A lawyer in that position has one genuinely good option: full, immediate, unqualified disclosure. Watkins chose the other path, and the court's order reads like a catalogue of why that path costs more.

Same tool, same judge, different lawyer

This is not the first time Judge Manasco's courtroom has featured AI-fabricated citations; she also handled the sanctions in the Butler Snow matter involving fabricated citations in Alabama prison litigation. Two cases from the same judge is not a coincidence so much as a sign of how common the underlying failure has become, and how consistently courts are responding once they see it.

The recurring theme across all of these cases is that generative AI does not retrieve law; it generates text shaped like law, and a lawyer who files that text without checking it is vouching for citations he has never actually read. Watkins compounded that by vouching for it again, and again, after being told it was fake. The tool wrote the fiction. He kept it going.