Judge Kai N. Scott sanctioned defense lawyer Raja Rajan $5,000 on April 20, 2026 after finding that he had again filed AI-generated fake citations in Bunce v. Visual Technology Innovations. Rajan had already been fined $2,500 and ordered to complete AI and legal ethics CLE in the same litigation the year before. This time the judge said she remained appalled by the conduct, ordered more CLE, and warned that a third incident could trigger referral to the Pennsylvania Disciplinary Board. The notable part is not that AI got something wrong. It is that a lawyer, after already being punished for the exact same mistake, did it again.

In April 2026, Sullivan & Cromwell told a Manhattan bankruptcy judge that an emergency motion it filed in the Prince Global Holdings Chapter 15 case contained AI hallucinations, inaccurate citations, and other errors. Opposing counsel at Boies Schiller Flexner caught the problems first. Andrew Dietderich, co-head of the firm's restructuring practice, apologized in a letter dated April 18, said the firm's AI policies had not been followed, and acknowledged that a secondary review also failed to catch the bogus material. The corrected filing avoided an immediate sanctions story, but it still turned one of Wall Street's prestige firms into the latest exhibit in why AI-assisted legal drafting and vibes-based review are a bad mix.

In Couvrette v. Wisnovsky, an Oregon federal estate dispute turned into one of the harshest AI-lawyering cases yet. Across three summary-judgment briefs, plaintiffs' counsel used 15 fake case citations and eight fabricated quotations. Magistrate Judge Mark Clarke sanctioned the lawyers in December 2025, split a $94,704.38 fee award between lead and local counsel on March 23, 2026, and dismissed the case with prejudice a week later. The filing error was bad enough. What made this one worse was the court's view that the problems were flagged, not meaningfully fixed, and left to rot until the court stepped in.

Salem attorney Bill Ghiorso was fined $10,000 by the Oregon Court of Appeals after submitting an opening brief in Doiban v. Oregon Liquor and Cannabis Commission that contained at least 15 fabricated case citations and nine nonexistent legal quotations - all generated by an AI search tool used by his staff. The fine is the largest ever imposed in Oregon for AI-related errors in legal filings, calculated under a penalty structure the court established in December 2025: $500 per fake citation, $1,000 per fake quote. The intended total of $16,500 was capped at $10,000 due to Ghiorso's medical issues. Perhaps the most instructive detail: when Ghiorso's staff asked the AI tool whether its own fabricated citations were real, it helpfully confirmed they were.

The Sixth U.S. Circuit Court of Appeals sanctioned attorneys Van R. Irion and Russ Egli $15,000 each in punitive fines - totaling $30,000 - after their briefs in Whiting v. City of Athens, Tennessee contained more than two dozen fabricated or seriously misrepresented citations. The panel also ordered them jointly liable for the appellees' full attorney fees on appeal and double costs. The court didn't explicitly pin the fabrications on generative AI, but emphasized that lawyers must personally read and verify every citation "regardless of how they were generated" - which is a very specific way to phrase a very pointed implication.

Ontario lawyer Khalid Parvaiz was referred to the Law Society of Ontario by Justice Frederick Myers after filing a factum containing seven "wholly made up" quotations attributed to real court cases. Parvaiz claimed the fabricated passages were "human errors" from "misreading of the cases" and denied using AI. Justice Myers was unconvinced, noting the alleged quotations were "completely made up" rather than paraphrased or miscited, and warned that the cover-up - if Parvaiz was being untruthful about the source - could carry more severe consequences than the original error.

Rudy Renfer, an assistant U.S. attorney in the Eastern District of North Carolina, resigned in March 2026 after admitting he used AI to rewrite a legal brief that contained fabricated citations, fictitious quotations, and misstatements of law. The opposing party - a pro se retired Air Force colonel suing over GLP-1 medication coverage under TRICARE - caught the fakes. At a show-cause hearing, the presiding magistrate judge expressed skepticism about Renfer's claim that he had reviewed the brief before filing, noting the fabrications appeared "intentionally designed" to support the government's argument. The matter was referred to the DOJ's Office of Professional Responsibility, and the district's U.S. Attorney issued an office-wide memo warning staff that "AI may hallucinate, but that does not excuse you from your obligations."

Nippon Life Insurance Company sued OpenAI after ChatGPT allegedly acted as a de facto lawyer for Graciela Dela Torre, an Illinois disability claimant who had already settled her case. When her real attorney told her the settlement couldn't be reopened, she asked ChatGPT if she'd been "gaslighted." The chatbot told her to fire her lawyer, helped her draft over 60 pro se filings across two federal cases, and produced fabricated case citations including an entirely invented case called "Carr v." something. Nippon is suing OpenAI for unauthorized practice of law under Illinois state law, arguing it spent huge amounts of time and money dealing with AI-generated litigation that should never have existed.

India's Supreme Court stayed a property-dispute ruling after discovering the trial court judge had relied on non-existent, AI-generated case citations. An Andhra Pradesh junior civil judge admitted using an AI tool for the first time without verifying the outputs. The Supreme Court termed the reliance on fabricated judgments as "misconduct" with "a direct bearing on the integrity of the adjudicatory process." Separately, the Bombay High Court fined a litigant 50,000 rupees for filing AI-generated submissions citing the non-existent case "Jyoti vs. Elegant Associates." The Chief Justice flagged an "alarming trend" of AI-fabricated judgments including one titled "Mercy vs Mankind."

The Civilian Board of Contract Appeals sanctioned a party in Louis J. Blazy v. Department of State (CBCA 7992) after discovering four non-existent legal decisions and four fabricated deposition excerpts in filings. The supposed direct quotations from witness testimony didn't appear on the cited transcript pages. When pressed, Blazy admitted the quotes were "constructed" and offered substitute testimony that didn't support the original wording. He also misrepresented existing case law by submitting real decisions as stand-ins for the fake ones, characterizing them as supporting principles they did not contain. The CBCA issued a formal admonishment and warned that continued misconduct could result in dismissal - making this one of the first federal sanctions involving AI-fabricated witness testimony, not just made-up case law.

The U.S. Court of Appeals for the Fifth Circuit sanctioned attorney Heather Hersh $2,500 after finding her brief contained 16 fabricated quotations and five additional serious misrepresentations of law or fact, all apparently AI-generated. The court expressed frustration that AI-hallucinated legal citations "have increasingly become an even greater problem in our courts" and that the issue "shows no sign of abating." Hersh initially denied using AI, then shifted to claiming she "relied on publicly available versions of the cases, which she believed were accurate."

Kenosha County District Attorney Xavier Solis was sanctioned by Circuit Court Judge David Hughes after his office submitted court filings containing AI-generated legal citations that did not exist. The filings were part of a burglary case against two defendants, and Solis failed to disclose his use of AI - violating Kenosha County's court policy requiring disclosure and verification of AI-generated content. The charges were ultimately dismissed (primarily for lack of probable cause), but not before the bogus citations made the DA's office a cautionary tale for prosecutors nationwide. Solis acknowledged the error and promised to "review and reinforce internal practices." It's always reassuring when the person responsible for prosecuting crimes can't be bothered to read the citations in their own filings.

Maryland attorney Kusmin Amarsingh used ChatGPT to draft her appellate brief against Frontier Airlines without verifying any citations, resulting in multiple nonexistent cases being cited in the 10th Circuit. The court found her conduct "reckless" for completely failing to perform "an attorney's fundamental duty to the court." She was fined $1,000 and referred to Maryland attorney-disciplinary authorities.

Attorney Steven Feldman filed multiple motions containing AI-fabricated case citations in Flycatcher Corp. v. Affable Avenue LLC. Despite explicit court warnings and access to Westlaw and Lexis, he continued submitting unverified AI output -- even using AI to draft his response to the court's show-cause order, which contained yet more fake citations. Judge Failla imposed the most severe AI-hallucination sanction yet: default judgment against his client.

A federal judge in the District of Kansas fined four attorneys a combined $12,000 for court filings containing AI-generated fabricated legal citations in a patent infringement case. The attorney who used ChatGPT received $5,000; two who failed to review the filings received $3,000 each; local counsel who did not identify errors received $1,000. The judge called the volume of fabricated case law "staggering."

Attorneys Yen-Yi Anderson and Jeffrey Goldin jointly filed a motion in Lifetime Well v. IBSpot containing at least eight AI-generated false citations. Judge Kearney imposed differential sanctions based on their responses: Anderson, who blamed time pressure and fired her law clerk rather than accepting responsibility, received $4,000 in monetary sanctions. Goldin, who promptly accepted responsibility and implemented remedial measures, received no monetary penalty.

A New York appellate court imposed $10,000 in sanctions after a lawyer submitted briefings in a mortgage foreclosure case containing fabricated case citations identified as likely AI-generated hallucinations. The court found multiple nonexistent cases and misrepresented holdings, affirming prior orders and awarding costs to the plaintiff.

Five attorneys who signed a legal brief for Lexos Media IP LLC in a patent infringement case against Overstock.com submitted fabricated case citations hallucinated by ChatGPT to a federal court in Kansas. Senior U.S. District Judge Julie Robinson issued an order requiring them to explain why they should not be sanctioned, with multiple defects attributed to AI including nonexistent lawsuits, made-up judicial quotes, and citations to real cases that held the opposite of what the brief claimed.

A federal judge in the Northern District of California sanctioned plaintiff's counsel James Dal Bon in Buchanan v. Vuori Inc. (Case 5:23-cv-01121-NC) for filing AI-generated case law citations in a motion for preliminary approval of a wage and hour class action settlement. Dal Bon used six different AI tools to prepare the memorandum, which contained hallucinated quotes and a nonexistent case citation. After the court flagged the fabricated citations, his corrected filing still contained AI-hallucinated case law. The sanctions delayed the class action settlement, ultimately converting it to an individual settlement that abandoned the class members the attorney was supposed to represent.

The Government Accountability Office dismissed three consolidated protests filed by Oready, LLC - the culmination of 15 pro se bid protests filed over eight months, all riddled with non-existent citations, fabricated decisions, and hallmarks of unverified generative AI output. The GAO labeled Oready's pattern as "Gen-AI Misuse" and dismissed the protests as an abuse of the bid protest process, marking the GAO's first published dismissal for AI-driven abuse. Prior warnings issued in June and August 2025 were ignored. The fallout also prompted the GAO's January 2026 decision in Bramstedt Surgical to devote several pages to cautioning against AI-hallucinated citations, signaling that federal procurement tribunals are done issuing gentle reminders.

Los Angeles attorney Amir Mostafavi became the first California lawyer sanctioned for AI-generated legal fabrications when a court hit him with a $10,000 fine. He ran his appeal draft through ChatGPT to improve the writing but did not verify the output before filing, unaware the tool had inserted fabricated case citations.

Gordon Rees Scully Mansukhani, one of the largest U.S. law firms, was caught filing AI-hallucinated case citations in an Alabama bankruptcy proceeding. An associate initially denied using AI under oath before the firm acknowledged the fabricated references and paid over $55,000 in sanctions and fees. Months later in February 2026, the same firm was reported to have filed a second brief containing hallucinated citations in a separate matter, making it the first Am Law 100 firm known to be a repeat offender.

On July 23, 2025, U.S. District Judge Anna Manasco sanctioned three Butler Snow lawyers after filings in an Alabama prison case cited authorities that did not exist. The court found the lawyers had used ChatGPT for legal research, failed to verify the output, removed all three from the case, ordered broad disclosure of the sanctions order to clients and courts, and referred the matter to the Alabama State Bar. It was not just another fake citation incident. It was a fake citation incident attached to one of the firms Alabama pays to defend its prison system in high-stakes civil rights litigation.

In Shahid v. Esaam, decided June 30, 2025, the Georgia Court of Appeals vacated part of a divorce-related order after finding that several cited authorities did not exist and others did not support the propositions claimed. The panel concluded the briefing showed the hallmarks of generative AI hallucination, fined attorney Diana Lynch $2,500, and sent the matter back to the trial court. What made the case stand out ran deeper than a sloppy brief: the fake citations appeared to have made their way into the trial court's signed order.

On June 6, 2025, the High Court of England and Wales issued a joint ruling in two separate matters after lawyers put fake authorities before the court. In one case tied to Qatar National Bank, a filing cited 45 authorities, 18 of which did not exist, while many of the rest were misquoted or irrelevant. In the other, a housing claim against the London Borough of Haringey included five fabricated cases. The Divisional Court, led by Dame Victoria Sharp, said tools such as ChatGPT are not capable of reliable legal research, referred the lawyers involved to their regulators, and warned that more serious future misuse could lead to contempt proceedings or even police referral. The ruling turned individual AI citation blunders into a profession-wide warning.

In Mata v. Avianca (S.D.N.Y.), plaintiff Roberto Mata sued the airline after a metal serving cart struck his knee during a 2019 flight. His attorney Peter LoDuca filed a brief opposing dismissal that cited six judicial decisions. When opposing counsel and the court couldn't locate any of the cited cases, Judge Kevin Castel demanded copies. It turned out attorney Steven Schwartz at the same firm had used ChatGPT to research and draft the brief, and the AI had fabricated every case, complete with fake quotes and fake internal citations. On June 22, 2023, Castel sanctioned Schwartz, LoDuca, and their firm Levidow, Levidow & Oberman with a $5,000 penalty and required them to send notices to the real judges whose names appeared in the fabricated opinions.