AI Hallucination Cases
US courts are deciding AI hallucination and sanctions cases at an accelerating pace. This tracker publishes a reference page per case with links to dockets, orders, and the related state bar rules or court standing orders that apply.
Covers monetary sanctions, bar discipline referrals, disqualifications, license suspensions, pro hac vice revocations, and pending cases where the appellate court has not yet ruled.
For the chronological view across all three trackers and federal AI guidance, see the AI legal regulation timeline.
+16 nationwide cases bind every state and don't show on the map (Zhejiang Dingli Machinery Co., Ltd. v. United States , In the Matter of Brian E. Mitchell , Appeal of PDO Ahuska Joint Venture LLC , +13 more).
About the map
The map highlights the strictest case binding each state. Color encodes severity; the count and breakdown appear in the tooltip. Nationwide tribunals (USPTO, JPML, EOIR, Tax Court) are tracked in the count and breakdown but excluded from the color so they don't wash out the per-state signal. On smaller states (RI, CT, DE, DC), use the "Choose state" picker below the map or keyboard arrow navigation from a focused neighbor. The map satisfies WCAG 2.5.8 via the picker (44 px+ touch targets for every state) and the keyboard adjacency map.
The AI tool filter matches text in each entry's AI tool field, which is recorded as free text and often includes the court's own qualifications. A match means the field mentions the product, not that the filer used it.
Showing 790 of 790 cases.
| Case | Court | Date | AI Tool | Outcome | Amount | Verified |
|---|---|---|---|---|---|---|
| Garcia v. City of Monte Vista | D. Colo. U.S. District Court, District of Colorado | Sep 2026 | Generative AI, no tool named (counsel's declaration, as the sanctions order recounts it, states he used generative AI "primarily to help identify potentially relevant cases" and attributes the misquotation to his own notes rather than to AI; the court states it "has no way of knowing" which produced it and accepts his representations) | Court sanction | Nonmonetary: all future filings by the Law Office of Troy D. Krenning, LLC and/or Troy D. Krenning must contain an AI Certification on the use or non-use of generative AI, signed by everyone who drafted the filing; plus an express warning of harsher sanctions, including monetary sanctions | Sep 2026 |
| Aguilar v. The Crawford Group, Inc. | D. Mass. U.S. District Court, District of Massachusetts | Sep 2026 | Unnamed AI software (the court recounts that counsel admitted using AI to draft the opposition to the motion to strike, believing the enterprise-level version he used did not hallucinate cases; the court found it irrelevant that he had not admitted using AI in the Enterprise and Travelers oppositions) | Court sanction | The Lindemann Law Firm to pay the Enterprise Defendants' reasonable fees and costs for (a) replying to the opposition to their motion to strike, (b) filing the sanctions motion and its reply, and (c) replying to the opposition to their motion to dismiss, not to exceed $10,000; pro hac vice admission of attorney Blake Lindemann revoked | Sep 2026 |
| Cervantes v. Bianco | Cal. Supreme Court of California | Sep 2026 | Unidentified (the court says the "improper use of artificial intelligence tools" apparently contributed to the error but names no tool) | Warning | None | Oct 2026 |
| Koeberer v. Weir | 6th Cir. U.S. Court of Appeals for the Sixth Circuit | Sep 2026 | Unidentified (the opinion addresses "problematic citations" identified in a show-cause order but does not attribute them to AI or name a tool) | Warning | None | Sep 2026 |
| Dean v. Commissioner of Social Security Administration | D. Ariz. U.S. District Court, District of Arizona | Sep 2026 | Suspected (the court states the missing quotation "raises a concern that the Commissioner has provided an AI-hallucinated quotation"; no finding, no admission, no tool named) | Other | None; the court noted the concern in a footnote and imposed no sanction, show-cause, or directive | Sep 2026 |
| Garner v. Transit Employees Federal Credit Union | D.D.C. U.S. District Court, District of Columbia | Sep 2026 | Unidentified (the court orders counsel to explain "whether he used generative artificial intelligence when writing his brief"; no finding or admission of AI use) | Pending | None imposed as of the September 22, 2026 order; show-cause response due October 6, 2026 | Sep 2026 |
| Posey v. Bushnell | Idaho Sup. Ct. Supreme Court of Idaho | Sep 2026 | Suspected, not found (the Court said the errors "suggest that she may have relied on generative artificial intelligence"; Bushnell maintained she did not, and the Court said her briefing and the record "raise serious doubt as to that assertion") | Other | None | Sep 2026 |
| Zhejiang Dingli Machinery Co., Ltd. v. United States | U.S. Court of International Trade | Sep 2026 | Unidentified (the court says the statements are "so outlandish as to appear to be the product of hallucination, either by a human being or by artificial intelligence" and, if the plaintiff cannot substantiate them, requires declarations on who "or what, including artificial intelligence or other software program" wrote them; no finding of AI use) | Pending | None imposed as of the September 22, 2026 order; plaintiff to substantiate within 14 days or show cause under USCIT Rule 11(b)(3) | Sep 2026 |
| Englert v. Gateway Crossing Property Owners Association, Inc. | Ind. Ct. App. Court of Appeals of Indiana | Sep 2026 | Unidentified (the decision records nonexistent and miscited cases and notes that the trial judge commented on "the dangers of relying on artificial intelligence" for legal research, but makes no finding that Englert used AI) | Court sanction | Fee award under Ind. Code 34-52-1-1 for frivolous, unreasonable, and groundless claims (trial court award, affirmed; the Court of Appeals found the nonexistent and miscited case law critical to the frivolousness conclusion); appellate fees denied; amount in the outcome | Sep 2026 |
| In re Estate of Ruth M. Gerdes | Ill. App. 2d Dist. Appellate Court of Illinois, Second District | Sep 2026 | Suspected generative AI (the court states the fictitious authorities have "led us to believe appellee's attorney used generative artificial intelligence (AI) to draft his brief"; no admission of use, no tool named) | Pending | None imposed as of the September 18, 2026 order; rule to show cause entered under Ill. S. Ct. R. 375, with any sanction to follow in a separate written order | Sep 2026 |
| Whitfield v. Prime Agency, LLC | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Sep 2026 | Suspected (the court describes passages "with characteristics consistent with artificial intelligence hallucinations" and notes counsel has not explained what tools, "including any artificial intelligence tools, if applicable," were used; no finding or admission of AI use) | Pending | None imposed as of the September 18, 2026 order; show-cause response due October 2, 2026 and hearing set for October 15, 2026 | Sep 2026 |
| Parvaz v. KNJ Realty, Inc. | Sup. Ct. Kings County (N.Y.) Supreme Court of the State of New York, Kings County | Sep 2026 | Unidentified (the court records that the filer "was candid when asked by the court if he had used AI" and refers to "hallucinated citations"; no tool is named) | Warning | None; the court issued "a stern reprimand" and, "[i]n lieu of sanctions," required counsel to file a verified statement, under penalty of perjury, within seven days | Sep 2026 |
| Risner v. Starke County | N.D. Ind. U.S. District Court, Northern District of Indiana, South Bend Division | Sep 2026 | Unidentified (a footnote states that an inconsistency between the complaint and the briefing "appears to have arisen from Plaintiffs' use of AI in drafting their pleading documents"; no tool named) | Other | None; the court noted the apparent AI use in a footnote and imposed no sanction or warning | Sep 2026 |
| Lisandrillo v. Palozzi | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | Sep 2026 | Suspected AI (the court states "We suspect that counsel's filings contain AI-generated components" and suspects AI generated arguments from an unofficial transcript; no finding or admission of use, no tool named) | Pending | None imposed as of 2026-09-29; order to show cause pending on whether sanctions, "such as referral to the Florida Bar for consideration of disciplinary proceedings," should be imposed under Fla. R. App. P. 9.410(a) | Sep 2026 |
| Bell v. City of Clairton | W.D. Pa. U.S. District Court, Western District of Pennsylvania | Sep 2026 | Lexis AI (the court recounts that counsel's show-cause response stated she used Lexis AI to prepare and draft the brief, and that she reconfirmed at the hearing she used Lexis's AI software; the court found the "Source" citations "seemingly produced by Lexis Source Link" and the brief's metadata title was "AI Assistant Response") | Court sanction | Non-monetary: four hours of CLE on artificial intelligence and legal ethics (in addition to Pennsylvania's annual requirement), with proof of completion, and CM/ECF filing training with the Clerk's Office; warning that fines will follow if practices are not remedied | Sep 2026 |
| Henry v. Long Island University | E.D.N.Y. U.S. District Court, Eastern District of New York | Sep 2026 | Unidentified (the court refers to "what appears to be counsel's reliance on artificial intelligence"; no tool is named and no AI use is admitted in the order) | Court sanction | No monetary sanction; for two years, attorneys Karen Lynn Mizrahi and Brett R. Leitner must file a copy of the opinion in any E.D.N.Y. case in which they appear | Sep 2026 |
| Tiekert v. Village of Mamaroneck | S.D.N.Y. U.S. District Court, Southern District of New York | Sep 2026 | ChatGPT (counsel acknowledged relying on it to research and draft the oppositions) | Court sanction | $500 payable to the Clerk of Court; two New York CLE credits in Ethics and Professionalism on AI by December 31, 2026; a GenAI-use certification on any future filing in the court researched or drafted with GenAI; service of the order on the client | Sep 2026 |
| Virgil v. Experian Information Solutions, Inc., et al. | S.D. Ind. U.S. District Court, Southern District of Indiana, Indianapolis Division | Sep 2026 | Not admitted or found (counsel attributed the errors to cutting and pasting from prior-case documents; the district court said it is difficult to see how that accounts for errors that are often "hallmarks of AI hallucinations" and held the source irrelevant) | Court sanction | $10,000 personal Rule 11 sanction against attorney James Policchio, payable to the Clerk within 30 days; matter referred to the Indiana Attorney Disciplinary Commission | Sep 2026 |
| Beus Gilbert PLLC v. Brigham Young University | D. Utah U.S. District Court, District of Utah | Sep 2026 | ClearBrief, Claude, ChatGPT, and Gemini, named as included among the models used (drafting attorney's statement at the show-cause hearing) | Court sanction | $2,000 penalty and two AI-ethics CLE courses for attorney Chad Pehrson; $1,000 penalty for attorney Robert S. Clark; both payable to the court with proof of payment within 30 days | Sep 2026 |
| Fay v. Warren Hospitality Suites, Inc. | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Sep 2026 | Generative AI (counsel acknowledged it was used to draft the motions in limine and responses; tool not named) | Court sanction | $10,000 fine, jointly against plaintiff's attorney Schroeder and McKeen & Associates, P.C., payable to the court Clerk; plaintiff may not bear any part of it, including through her settlement | Sep 2026 |
| Pennmark Coventry Holdings, LLC v. Kohl's Department Stores, Inc. | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Sep 2026 | Suspected (the court "questions whether this is merely an error by counsel, or whether Plaintiff may have relied upon a hallucinated quote from an artificial intelligence program"; no finding, no tool named) | Other | None; the court raised the question in a footnote and imposed no sanction, show-cause, or directive | Sep 2026 |
| State v. Sandoval (In re Stephen D. Aarons) | N.M. Sup. Ct. Supreme Court of New Mexico | Sep 2026 | ChatGPT (respondent acknowledged in his written response and at oral argument that he used "the generative artificial intelligence (AI) tool ChatGPT" to prepare the brief in chief) | Court sanction | $5,000 to the State Bar of New Mexico Client Protection Fund as a sanction for direct contempt; referral to the Disciplinary Board; barred from appearing before the Supreme Court pending the disciplinary proceedings; all briefing stricken | Sep 2026 |
| Youssian v. Village of Kings Point | N.Y. Sup. Ct. Supreme Court of the State of New York, Nassau County | Sep 2026 | Spellbook AI, a drafting tool embedded in Microsoft Word (counsel's explanation at the July 22, 2026 hearing, as the court recounts it) | Court sanction | $5,000 sanction payable to the Lawyer's Fund for Client Protection of the State of New York (as the order names it); attorney's fees of $8,000 to 22 Liam Properties LLC and $2,000 to the Village of Kings Point; petition and amended petition stricken and the proceeding dismissed | Sep 2026 |
| Asiedu v. Eastlund | Minn. Ct. App. Minnesota Court of Appeals | Sep 2026 | Unnamed AI research tool (per the Court of Appeals, Asiedu "admitted that he used artificial intelligence as a research tool to draft his filings" at the district court hearing) | Court sanction | $2,341.25 in respondents' reasonable costs and attorney fees, imposed by the district court under its inherent authority (affirmed) | Sep 2026 |
| G.P. v. Arevalo | W.D. Wash. U.S. District Court, Western District of Washington | Sep 2026 | Unidentified (the order notes erroneous citations that Turo "contends--and G.P. does not dispute--are likely the result of AI fabrication"; no tool named) | Warning | None | Sep 2026 |
| State ex rel. Schnell v. Richardson | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District | Sep 2026 | Generative AI, tool not named (the court recounts that counsel's show-cause response 'stated that she used generative artificial intelligence to research legal authorities') | Court sanction | $1,750 under Rule 55.03(c), payable by relator's counsel Jenna Rohr Conley to the petitioners in the underlying action for attorney's fees incurred in opposing the writ petition | Sep 2026 |
| Wurm v. Anchor Bay Packaging Corporation | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Sep 2026 | Unidentified (the court states the motions "have all the earmarks of having been generated by AI"; no tool named or admitted) | Warning | None | Sep 2026 |
| Douglas v. Deutsche Bank National Trust Company | D.C. Ct. App. District of Columbia Court of Appeals | Sep 2026 | Google's generative AI search tool (the filing attorney's own description) | Court sanction | Non-monetary: appellee's brief stricken; matter referred to the Office of Disciplinary Counsel | Sep 2026 |
| Falkenstein v. Niles | C.D. Cal. U.S. District Court, Central District of California | Sep 2026 | Generative AI, tool not named (counsel disclosed generative AI use for the reply and the preliminary-injunction opposition and certified that no portion of the motion to dismiss was drafted with it; the court has not found that AI caused the errors) | Pending | Pending | Sep 2026 |
| Cole v. Hobby Town Unlimited, Inc. | C.D. Ill. U.S. District Court, Central District of Illinois, Rock Island Division | Sep 2026 | Unnamed AI tool (counsel said he relied in part on prior work product "developed with the help of AI" as a drafting aid and template; the court describes the citations as hallucinated) | Court sanction | $1,000 fine payable to the Clerk of Court within 60 days; counsel ordered to send a copy of the order to the Illinois ARDC and to file a compliance status report within 60 days | Sep 2026 |
| Sea Swivel Inc. v. Shuttleslide LLC | S.D. Fla. U.S. District Court, Southern District of Florida | Sep 2026 | CoCounsel, apparently (the court noted the response was titled "CoCounsel Skill Results" and its metadata listed CoCounsel as author, calling this an "apparent use of AI"; it would not, "at this juncture," draw a causal link between that use and the miscited case) | Warning | None | Sep 2026 |
| Illinois Department of Healthcare and Family Services ex rel. Shona L. Williams v. Samuel R. Lee, II | Ill. App. Ct. (3d Dist.) Appellate Court of Illinois, Third District | Aug 2026 | Suspected generative AI (majority: the only case cited "appears either entirely fabricated by Samuel or hallucinated through his improper use of generative artificial intelligence (AI)"; tool not identified) | Warning | None | Sep 2026 |
| Booker v. The Kroger Co. | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Aug 2026 | Unnamed AI tools (counsel denied AI use at a hearing, then acknowledged in his show-cause response that he "consulted" AI tools) | Court sanction | $8,000 fine to the court registry's general sanctions fund ($1,000 for each of four authorities, doubled for lying to the court); documentation of completed ethics and technology CLE due within 7 days | Sep 2026 |
| Disciplinary Counsel v. Agee | Ohio Bd. Prof. Conduct Board of Professional Conduct of the Supreme Court of Ohio | Aug 2026 | Unnamed AI application (the complaint alleges that respondent "used artificial intelligence" to write the motion; his answer admits he "used artificial intelligence (AI) to assist in writing the motion") | Pending | None yet; a certified complaint alleging violations of Prof.Cond.R. 1.1 and 3.3(a)(1) is pending, with a formal hearing set for January 22, 2027 | Sep 2026 |
| Reyes v. Bailey | D.N.M. U.S. District Court, District of New Mexico | Aug 2026 | Unidentified (the order's only AI-related reference is its summary of the pro se plaintiff's contention that defendants misrepresented that he "hallucinated a case citation"; the court makes no AI finding) | Other | None; the court denied the pro se plaintiff's motion for sanctions against defendants and denied defendants' fee request | Sep 2026 |
| Adams v. Matrix Providers Inc. | D. Colo. U.S. District Court, District of Colorado | Aug 2026 | Unidentified (the court states it is "unclear" whether the misstatements resulted from "the use of an AI legal search, or simply poor and unexacting legal judgment") | Warning | None | Sep 2026 |
| James v. Conley | S.D. Fla. U.S. District Court, Southern District of Florida | Aug 2026 | Unnamed "AI-augmented" research (plaintiff's response conceded the training-key allegations rested on unverified AI-generated research; no tool named) | Pending | Pending | Sep 2026 |
| Kiser v. DeSimone Auto Group | Pa. Super. Ct. Pennsylvania Superior Court | Aug 2026 | Unidentified (quoting an earlier Superior Court decision, the court said it was left to guess whether the "counterfeit authority is the product of a chatbot" or had a more nefarious explanation; it made no finding of AI use) | Other | None | Sep 2026 |
| Varma v. The Bank of New York Mellon | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division Two | Aug 2026 | Generative AI (the appellants' written responses said they relied on "artificial intelligence research tools"; the court credited their later account that a paid nonlawyer drafted the brief and that they "were unaware that she used generative AI"; tool not identified) | Court sanction | Appellants ordered to pay the Bank of New York Mellon's appellate attorney fees as a sanction under Cal. Rules of Court, rule 8.276(a)(4), amount to be set by the trial court on remand; opinion forwarded to the State Bar regarding possible unauthorized practice of law by the nonlawyer drafter, Trina Patterson | Sep 2026 |
| Williams v. Dallas-Fort Worth International Airport Board | N.D. Tex. U.S. District Court, Northern District of Texas, Fort Worth Division | Aug 2026 | Unidentified (footnote 2 cautions that "use of generative artificial intelligence that results in repeated misrepresentations of law may qualify for sanctions"; the order does not find that AI was used or name a tool) | Warning | None; the court called plaintiffs' citations "a borderline sanctionable attempt" and cautioned in a footnote that AI use resulting in repeated misrepresentations of law may be sanctionable | Sep 2026 |
| Shelbert v. Baxter International, Inc. | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Aug 2026 | Unidentified (the court wrote that "[t]he presumable conclusion was that Tyler had AI review Baxter's Answer and had it generate his Motion to Strike"; no admission and no tool named) | Warning | None; admonishment under the court's inherent authority and notice under Rule 11, stated to serve as both parties' warning | Sep 2026 |
| Turgeon v. Federal Home Loan Mortgage Corporation | D.N.H. U.S. District Court, District of New Hampshire (appeal from the U.S. Bankruptcy Court) | Aug 2026 | Unidentified (the bankruptcy court described "false, hallucinated case citations"; neither court attributes them to AI or names a tool) | Court sanction | Not stated | Sep 2026 |
| Benjamin v. State of Maryland | Md. App. Ct. Appellate Court of Maryland | Aug 2026 | Unidentified (the court wrote that counsel "has not admitted that the mistakes in the brief were due to the use of AI, but that seems likely"; no tool named) | Warning | None; the court declined to refer counsel to the Attorney Grievance Commission and urged counsel to use AI responsibly and check all citations | Sep 2026 |
| LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC | Va. Ct. App. Court of Appeals of Virginia | Aug 2026 | Unidentified (the court concluded the phantom quotations came from "some form of computer-assisted research that went awry" and discussed AI at length; the opinion names no tool) | Court sanction | No monetary sanction; appellee's counsel directed to complete a continuing legal education course relating to AI or appellate practice within six months, under Code § 8.01-271.1 | Sep 2026 |
| Ruiz v. Magellan Financial & Insurance Services | D. Ariz. U.S. District Court, District of Arizona | Aug 2026 | ChatGPT (named in counsel's response for two of the four affected filings; the court describes the errors in all four as AI-generated) | Court sanction | Formal public reprimand, which counsel must report wherever she is required to report past attorney discipline | Sep 2026 |
| Capital Standard, LLC v. U.S. Bank National Association | Fla. 2d DCA District Court of Appeal of Florida, Second District | Aug 2026 | Unnamed generative AI tool (counsel described it as "a supplemental research tool"; the court found it was his "primary or only one") | Court sanction | $1,500 fine against attorney Kenneth H. Keefe ($500 for a belated show-cause response, $1,000 for AI misuse), payable within 14 days; personal liability for U.S. Bank's appellate fees for answering the amended initial brief (amount on remand); may not be charged to clients; referral to The Florida Bar | Sep 2026 |
| Disruptive Resources, LLC v. Ballistic Barrier Products Inc. | D. Del. U.S. District Court, District of Delaware | Aug 2026 | Strongsuit (counsel's self-disclosed use to outline a reply brief and pull supporting deposition statements) | Warning | None | Sep 2026 |
| Dotson v. Bob Evans Farms, LLC | C.D. Cal. U.S. District Court, Central District of California | Aug 2026 | Unidentified (the court said the misattributed quotations "bear the hallmarks of hallucinated cases created by artificial intelligence" and ordered counsel to declare whether generative AI was used; no tool named) | Pending | None imposed in this order; order to show cause re monetary sanctions and State Bar referral of Todd M. Friedman set for August 28, 2026 | Sep 2026 |
| Full Standard Properties, LLC v. SJ 6070, LLC | N.D. Cal. U.S. District Court, Northern District of California, San Jose Division | Aug 2026 | Unidentified (the orders flag citations to nonexistent cases but do not attribute them to AI or name a tool) | Other | No sanction imposed; order to show cause discharged after plaintiff's counsel reimbursed defendant $14,500 in attorneys' fees by informal agreement | Sep 2026 |
| Cain v. Hyatt Corporation d/b/a Hyatt Regency Resort Lost Pines Spa and Resort | W.D. Tex. U.S. District Court, Western District of Texas, Austin Division | Aug 2026 | Unidentified (neither the show-cause order nor the order declining sanctions mentions AI or names a tool; both call the cited case nonexistent) | Other | None | Sep 2026 |
| Snisko v. Cascade Funding Mortgage Trust HB4 | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division (appeal from the U.S. Bankruptcy Court) | Aug 2026 | Unidentified (the order refers to "fabricated legal citations" and false quotations but does not mention AI or name a tool) | Pending | None yet; appellant's counsel Martin Spencer ordered to show cause why he should not be sanctioned, response due September 9, 2026 | Sep 2026 |
| Wilkinson v. Schmelzer | Iowa Ct. App. Iowa Court of Appeals | Aug 2026 | Alleged by the appellee; not found (the court found no hallucinated case and could not say whether one nonexistent rule citation was "a simple typo or the result of unchecked AI use") | Warning | None; sanctions declined. Separately, the appellee was awarded all of her requested appellate attorney fees as the prevailing party, and all costs were assessed to the appellant | Sep 2026 |
| Garcia Perez v. Blanche | W.D. Tex. U.S. District Court, Western District of Texas, Austin Division | Aug 2026 | Unidentified (the order says "an alarming number" of the Reply's cited cases are "nonexistent, 'hallucinated' cases" and cautions that "future inaccurate citations 'hallucinated' by generative artificial intelligence tools may result in sanctions"; it names no tool and makes no express finding about how the citations were produced) | Warning | None | Sep 2026 |
| In re Marriage of Muriel and Farris | Wash. Ct. App. Washington Court of Appeals, Division Two | Aug 2026 | Suspected generative AI, tool not named (the court wrote: "We surmise that Jonathan used artificial intelligence (AI) to assist in writing his brief, which resulted in an 'AI hallucination.'") | Court sanction | Appellant's appellate attorney fees for time spent reviewing and responding to the respondent's brief, awarded under RAP 18.9(a); amount to be determined by the commissioner under RAP 18.1(f) | Sep 2026 |
| Kourradi v. Wyatt Brian Christopher d/b/a NXT-L3VL Mobile Mechanic Fab and Performance | Tex. App. (1st Dist.) Court of Appeals of Texas, First District (Houston) | Aug 2026 | "Legal Research AI" tool, per the court's July 16, 2026 strike order, which observed that the corrected brief filed February 11, 2026 "appears to have been prepared with the assistance of" it; the August 18, 2026 opinion makes no AI finding about the fourth brief, concluding only that "[t]he nature of the errors suggests that each of the foregoing legal citations is, at best, partially fabricated" | Court sanction | Non-monetary: appellant's fourth brief struck and appeal dismissed for want of prosecution under Tex. R. App. P. 38.9(a) and 42.3(b) (the opinion does not describe this as a sanction) | Sep 2026 |
| Boettcher v. Boettcher | Ariz. Ct. App. Arizona Court of Appeals, Division One | Aug 2026 | Unidentified (the opinion strikes an apparently false quotation and cites Acciavatti's hallucinated-citation holding, but does not attribute the quotation to AI) | Other | None; the apparently false quotation was struck and the court declined to impose sanctions | Sep 2026 |
| Brankle v. Schmell | Ind. Ct. App. Court of Appeals of Indiana | Aug 2026 | ChatGPT or another AI tool (trial court's inference, quoted by the Court of Appeals: the citations led the trial court "to opine that Brankle is using ChatGPT or other form of artificial intelligence"; no admission noted in the decision) | Court sanction | $1,546.00 of the defendant's motion-to-compel expenses under Ind. Trial Rule 37(A)(4) (trial court award, affirmed); remand for the defendant's reasonable appellate attorneys' fees under the same rule | Sep 2026 |
| Guerra Quezada v. United States | 5th Cir. U.S. Court of Appeals for the Fifth Circuit | Aug 2026 | Unidentified (the opinion flags a quotation the court could not locate in any opinion and several misattributed authorities but does not mention AI) | Warning | None | Sep 2026 |
| Chapman v. City of Priceville | N.D. Ala. U.S. District Court, Northern District of Alabama, Northeastern Division | Aug 2026 | Unidentified (the court states in a footnote that "it appears likely from the nature of the misrepresentations that the filings at issue were generated by artificial intelligence"; counsel attributed the drafting to his non-lawyer client) | Court sanction | Public reprimand; copy of the order to opposing counsel and the presiding judge in every pending case in which counsel is of record, and to the client; order submitted for publication in the Federal Supplement | Sep 2026 |
| In re Bard Implanted Port Catheter Products Liability Litigation | D. Ariz. U.S. District Court, District of Arizona | Aug 2026 | ChatGPT (plaintiffs' expert Dr. Ahmed El-Ghannam acknowledged at deposition that he used "all engines, including ChatGPT"; defendants identified no hallucinated citation in the report at issue) | Other | None; the AI-based challenge to the expert was rejected | Sep 2026 |
| JMOR Properties, LLC v. Artist Alley Townhomes, LLC | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | Aug 2026 | Unnamed AI software (the court recounts that counsel explained his normal process is to have "artificial intelligence ("AI") software research and draft the initial document," and that he alleged he filed the unrevised AI draft by mistake) | Court sanction | Non-monetary: referral of counsel Barry M. Leff to The Florida Bar for consideration of disciplinary proceedings | Sep 2026 |
| Suva v. Suva | Cal. Ct. App. (4th Dist. Div. 3) California Court of Appeal, Fourth Appellate District, Division Three | Aug 2026 | Unidentified (the court said the misquoted authorities "could be an instance of counsel improperly using artificial intelligence (AI) to assist in brief writing or there could be another explanation"; no finding and no tool named) | Warning | None | Sep 2026 |
| Stephen J. Palumbo and Lori A. Palumbo v. Gregory M. Palumbo | Del. Ch. Delaware Court of Chancery (Magistrate in Chancery) | Aug 2026 | Unidentified (the Magistrate observed that fictitious quotations are "one of the hallmarks of Artificial Intelligence usage"; no finding that AI was used and no tool named) | Pending | Fees and costs shifted to petitioners under the bad-faith exception to the American Rule (amount not stated); recommended in a Magistrate's final report | Sep 2026 |
| WRI Summit REIT LP v. Kuerschner | Ariz. Ct. App. Arizona Court of Appeals, Division One | Aug 2026 | Suspected generative AI (the court stated the errors are "consistent with the misuse of generative AI"; no finding, admission, or tool) | Court sanction | Appeal dismissed under ARCAP 25; personal representative awarded reasonable appellate attorney fees and taxable costs under ARCAP 25 (amount to be set under ARCAP 21); late corrective motion denied | Sep 2026 |
| Brown v. Real Estate Capital of America, LLC | N.Y. Sup. Ct. Supreme Court of the State of New York, New York County | Aug 2026 | Alleged by movants only (movants Su and RECAP asserted the quotation was fabricated by AI; the court did not decide whether it was "an AI fabrication, rather than the product of ordinary human error") | Other | None; request for attorney fees as a sanction denied | Sep 2026 |
| Smith v. Polk County | W.D.N.C. U.S. District Court, Western District of North Carolina, Asheville Division | Aug 2026 | Disputed and unidentified (counsel denied using AI for legal research and said an AI program "embedded in her practice" cannot hallucinate, but did not name it; the court found the origin of the fabricated quotations "remains a mystery") | Warning | None | Sep 2026 |
| Mohamed Ali v. Saeed Osman | N.D. Sup. Ct. Supreme Court of North Dakota | Aug 2026 | Unidentified (the opinion sanctions "multiple fictitious or nonexistent citation errors" but does not mention AI or attribute the errors to any tool) | Court sanction | $1,000 sanction payable by the appellant to the appellee (N.D.R.App.P. 13) | Sep 2026 |
| Burgess v. Greater Cleveland Regional Transit Authority | N.D. Ohio U.S. District Court, Northern District of Ohio, Eastern Division | Aug 2026 | Suspected, not found (the court "strongly suspects that AI was used to draft the Opposition" and said the citation "bears the hallmarks of a hallucinated case citation"; no tool named) | Warning | None | Sep 2026 |
| City of Murfreesboro v. BFI Waste Systems of Tennessee, LLC | M.D. Tenn. U.S. District Court, Middle District of Tennessee, Nashville Division | Aug 2026 | Unnamed AI tools (counsel confirmed that a major factor was the failure to check content generated through tools using artificial intelligence) | Court sanction | Public reprimand and $1,500 payable to the Clerk of Court within 30 days (attorney Louis W. Ringger III) | Sep 2026 |
| In re Garcia-Martz | Bankr. N.D. Ind. U.S. Bankruptcy Court, Northern District of Indiana, South Bend Division | Aug 2026 | Unidentified (neither the June 10, 2026 decision nor the August 6, 2026 order mentions AI; the court flags a nonexistent rule, a quotation not found in the cited case, and misstated case law) | Other | None | Sep 2026 |
| Isles v. Family Dollar | Ariz. Ct. App. Arizona Court of Appeals, Division One | Aug 2026 | Unidentified (the decision says only "[t]o the extent Isles relied on artificial intelligence in preparing her briefing"; it makes no finding of AI use) | Warning | No sanction for the citations; footnoted warning that future inaccuracies may draw ARCAP 25 sanctions. Separately, appellees awarded reasonable attorney fees under A.R.S. 12-349 and costs under A.R.S. 12-341 because the appeal lacked substantial justification | Sep 2026 |
| San Antonio Independent School District v. Becerra | Tex. App. (4th Dist.) Court of Appeals of Texas, Fourth District (San Antonio) | Aug 2026 | Generative AI, as the court's assessment (four cited opinions "appear to be hallucinations created by generative artificial intelligence"); no tool named and no admission of AI use recorded | Warning | None | Sep 2026 |
| Barteca Holdings LLC v. Tacobarn Newtown LLC | D. Conn. U.S. District Court, District of Connecticut | Aug 2026 | Open Law, Claude and ChatGPT (counsel explained at the show-cause hearing that he used them for suggestions on a brief he first drafted himself) | Court sanction | $3,500 deposited with the Clerk of Court; referral to the District of Connecticut Grievance Committee under Local Rule 83(c)(2); Westlaw or Lexis hyperlinks required for every authority in defendants' future filings | Sep 2026 |
| Cristancho v. SWBC Mortgage Corp. | S.D. Tex. U.S. District Court, Southern District of Texas, Galveston Division | Aug 2026 | Unidentified (the memorandum and recommendation calls two cited cases fabricated but does not attribute them to AI or name a tool) | Warning | None | Sep 2026 |
| De Ford v. Koutoulas | M.D. Fla. U.S. District Court, Middle District of Florida (Orlando Division) | Aug 2026 | Not identified (the court said it "believes" the cited cases were "hallucinated from Artificial Intelligence" and later found fabricated authority in at least eight filings, but made no finding of AI use; no admission recorded) | Court sanction | Default judgment against defendant James Koutoulas on the Third Amended Complaint; plaintiffs' reasonable attorneys' fees and costs for his discovery violations, amount to be set on motion | Sep 2026 |
| Forney v. Township of Cary, North Carolina | E.D.N.C. U.S. District Court, Eastern District of North Carolina, Western Division | Aug 2026 | Unidentified (the order sanctions fabricated legal authority but does not attribute it to AI or name a tool) | Court sanction | Attorney's fees the Town of Cary incurred as a result of counsel's brief (amount to be set on a later fee submission); referral to the North Carolina State Bar with the hearing transcript | Sep 2026 |
| Higgins v. State | Tex. App. (12th Dist.) Court of Appeals of Texas, Twelfth District (Tyler) | Jul 2026 | Unidentified AI; the opinion recounts that trial defense counsel "admitted that the memorandum was produced by artificial intelligence and he did not read the cases cited therein"; counsel later testified that he used AI to transcribe discovery videos and "to generate memoranda regarding legal issues" | Other | None | Sep 2026 |
| In re Mahar; Mahar v. New Rez LLC d/b/a Shellpoint Mortgage Servicing | Bankr. E.D. Va. U.S. Bankruptcy Court, Eastern District of Virginia, Norfolk Division | Jul 2026 | Unidentified (the court's opinion flags a nonexistent case and incorrect citations but does not attribute them to AI or name a tool) | Other | None | Sep 2026 |
| Matter of Mendel S. v. Faigy S. | N.Y. Fam. Ct. Family Court of the State of New York, Kings County | Jul 2026 | Generative AI, tool not named (the court said counsel cited "hallucinated cases" and "suspected" they were produced through counsel's use of generative artificial intelligence; counsel took "sole responsibility for submitting hallucinated cases") | Court sanction | $1,000 payable by counsel to the Lawyers' Fund for Client Protection of the State of New York within 20 days; no referral to the Attorney Grievance Committee | Sep 2026 |
| TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor | Conn. Sup. Ct. Connecticut Supreme Court | Jul 2026 | ChatGPT (admitted; used to edit briefs drafted from LexisNexis research) | Court sanction | $2,000 total ($1,000 each from Attorney Ian G. Gottlieb and GLG Law, LLC) to the CT Bar Institute, Inc.; six additional CLE hours (three on generative AI); compliance report within six months | Sep 2026 |
| United States v. Karnezis | D. Or. U.S. District Court, District of Oregon | Jul 2026 | Not attributed to AI: the opinion records that defense counsel stated at the hearing that the misquotation "was not a result of using generative AI but rather an inadvertent mistake"; the court made no finding either way | Warning | None | Sep 2026 |
| Carey v. Breakell | D. Utah U.S. District Court, District of Utah | Jul 2026 | Suspected, not found: the court located citations "suggesting that the improper use of artificial intelligence may have occurred" and left the issue to the transferee judge; no tool is named and counsel's explanation, if any, is not recorded | Other | None | Sep 2026 |
| Cole v. Lee | Ill. App. Ct. (1st Dist.) Appellate Court of Illinois, First District, Fourth Division | Jul 2026 | Unidentified (the order flags miscited authorities and authorities cited for propositions they do not support, but does not attribute them to AI) | Court sanction | Non-monetary: appellant's brief stricken and appeal dismissed in the court's discretion under Illinois Supreme Court Rule 341 (the order does not describe this as a sanction) | Sep 2026 |
| In the Interest of Q.C. and P.C., Children | Tex. App. Court of Appeals of Texas, Second District (Fort Worth) | Jul 2026 | Unidentified (the opinion notes a citation to a nonexistent case and quotations "nowhere to be found in the cited case law" but does not attribute them to AI or name a tool) | Other | None; the court noted the defects in the text and a footnote and took no action on them | Sep 2026 |
| In the Interest of S.M.T. and S.J.T., Children | Tex. App. (14th Dist.) Court of Appeals of Texas, Fourteenth District (Houston) | Jul 2026 | Unidentified; the opinion states the brief was "either (1) the result of using artificial intelligence yielding hallucination citations or (2) a deliberate attempt to mislead this court" and says "I prefer to assume the use of AI rather than intentional deception"; no tool is named | Court sanction | Non-monetary: attorney Jerry Lytel Lavespere, III ordered to attend three hours of CLE on the dangers of the use of artificial intelligence in court filings (attended, not self-study, and in addition to the State Bar of Texas annual requirement) and to certify attendance to the court within sixty days | Sep 2026 |
| Ruiz v. Magellan Financial & Insurance Services | D. Ariz. U.S. District Court, District of Arizona | Jul 2026 | Claude AI (counsel's show-cause response, as quoted in the order, says she used Claude AI to research and prepare the brief; the court says further errors in three other briefs "may also be attributable to the misuse of generative AI") | Other | None | Sep 2026 |
| Scott v. Illinois Human Rights Commission | Ill. App. Ct. (1st Dist.) Appellate Court of Illinois, First District, Second Division | Jul 2026 | ChatGPT (counsel stated he "frequently use[s] a premier corporate subscription of ChatGPT" to "synthesize complex matters") | Court sanction | $15,000 against attorney Mason Cole ($1,500 for each of 10 false citations and quotations), payable to the clerk of the Appellate Court, First District, within 30 days; opinion sent to the Illinois Attorney Registration and Disciplinary Commission | Sep 2026 |
| Transcontinental Realty Investors, Inc. v. Moos | N.D. Tex. U.S. District Court, Northern District of Texas, Dallas Division | Jul 2026 | Suspected generative AI, tool not identified (the court wrote that the nonexistent authority was "likely the result of imprudent reliance on a generative artificial intelligence tool") | Warning | None; footnote admonition to counsel, noting that the attorney who signed the brief appears pro hac vice | Sep 2026 |
| In the Matter of Brian E. Mitchell | USPTO U.S. Patent and Trademark Office (Director; Office of Enrollment and Discipline) | Jul 2026 | Two generative AI tools, not named (per the stipulated facts, one to draft proposed claim constructions and a second to review the plaintiff's portion of the chart) | Bar discipline | Public reprimand by settlement; publication in the OED FOIA Reading Room and a notice in the Official Gazette; each side bears its own costs | Sep 2026 |
| Lichfield v. Kubler | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Jul 2026 | Assumed generative AI, tool not identified (the panel wrote that "we assume the use of generative artificial intelligence led to the misrepresentations of legal authority") | Warning | None; the panel held the brief failed to fully comply with 10th Cir. R. 46.5 but declined sanctions and cautioned counsel | Sep 2026 |
| LeDoux v. Outliers, Inc. | W.D. Wash. U.S. District Court, Western District of Washington | Jul 2026 | ChatGPT and Claude (per counsel's sworn declaration, as recounted in the July 24, 2026 sanctions order) | Court sanction | $3,000 personal sanction on attorney Jocelyn Stewart, payable to the Clerk; certification of verified citations on all later briefing in the case; copy of the order to the client | Sep 2026 |
| Almeida Porfirio v. Mullin | D.D.C. U.S. District Court for the District of Columbia | Jul 2026 | Suspected AI, tool not identified (the court wrote that the errors "bear the hallmarks of reliance on an artificial intelligence tool" but made no finding that anything improper was done) | Other | None; the court declined to make any finding or open an inquiry and left the matter to the transferee court | Sep 2026 |
| Hagan v. Black Diamond Experts, LLC | D. Utah U.S. District Court, District of Utah | Jul 2026 | Suspected AI, tool not identified (the court wrote that its inability to locate the case "suggests that this citation may be a hallucination of artificial intelligence") | Warning | None; the court admonished counsel and warned that sanctions may be imposed if any improper use of AI "is determined to have occurred in the future" | Sep 2026 |
| Thomas v. U.S. Department of Justice | E.D.N.C. U.S. District Court, Eastern District of North Carolina, Western Division | Jul 2026 | Unidentified (the court's July 23 order grants the defendants' motion to correct their "errant citation to a 'hallucinated' case," reciting the motion's own description; defense counsel's response says the citation most likely came from an internet search, possibly an AI-generated search result, and does not name a tool) | Other | None | Sep 2026 |
| Gouldy v. Chiasson | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | Jul 2026 | Unidentified (the opinion places the brief within a trend in which "it appears that many pro se litigants" are using AI platforms, and the show-cause order calls one citation "hallucinated"; neither finds that Gouldy used AI or names a tool) | Court sanction | Non-monetary: by order of Aug. 12, 2026, the Clerk is directed to no longer accept any paper filed by the appellant unless reviewed and signed by a member in good standing of the Florida Bar who certifies a good faith basis for each claim | Sep 2026 |
| Pamon v. United States Postal Service | N.D. Tex. U.S. District Court, Northern District of Texas, Dallas Division | Jul 2026 | Unidentified (the order upholds a magistrate judge's warning about AI use after two cited cases could not be found; it names no tool and makes no finding that AI was used) | Warning | None | Sep 2026 |
| D'Ambrosio v. Meta Platforms Inc. | 7th Cir. U.S. Court of Appeals for the Seventh Circuit | Jul 2026 | Suspected generative AI (the May 15 opinion says the brief's "mistakes and fictitious quotations bear the hallmarks of the misuse of generative artificial intelligence" but proceeds "regardless of how these particular errors came about"; the July 21 order describes "fictious quotations and misstatements of law apparently generated by artificial intelligence and not corrected by counsel"; no admission, no tool named) | Court sanction | $7,997.60 to the Rajala appellees ($6,712.50 attorney fees plus $1,285.10 double costs under Fed. R. App. P. 38), jointly and severally against D'Ambrosio, attorney Aaron Walner and Trent Law Firm, P.C.; $5,000 fine against Walner payable to the clerk under Fed. R. App. P. 46(c); show-cause as to attorney Marc Trent's oral-argument statements discharged; May 15 opinion forwarded to the Illinois ARDC | Sep 2026 |
| Evans v. Robertson | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Jul 2026 | Unidentified (the July 21, 2026 order strikes 'factitious citations' without mentioning AI; the magistrate judge's September 25, 2025 order called earlier factitious citations 'presumably a product of using artificial intelligence (AI) software') | Court sanction | Not stated | Sep 2026 |
| Khan v. Howard County Board of Appeals | Md. App. Ct. Appellate Court of Maryland | Jul 2026 | Unidentified (the opinion catalogs at least 40 citation irregularities, including non-existent cases and misquotations, but does not mention AI or name a tool) | Court sanction | Non-monetary: portions of the appellant's briefs struck; remaining arguments not reached | Sep 2026 |
| Kings Roofing NWFL, LLC v. Fusion Works Construction, LLC | Fla. 6th DCA Florida Sixth District Court of Appeal | Jul 2026 | Unidentified generative AI (the May 22, 2026 opinion says the Initial Brief "looks as if it was drafted with the assistance of generative artificial intelligence"; the July 20, 2026 order describes it as "apparently produced with the assistance of generative artificial intelligence"; no tool named) | Other | Non-monetary: matter referred to The Florida Bar "for any action it deems appropriate"; order to show cause discharged; the order does not call the referral a sanction and imposes no fine | Sep 2026 |
| Mbow v. Mackert | D. Md. U.S. District Court, District of Maryland | Jul 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Cames v. Lowe's Home Centers, LLC | M.D. Fla. U.S. District Court, Middle District of Florida, Orlando Division | Jul 2026 | Suspected AI, tool not identified (the court wrote that "the typos paired with the misstatements of the holdings raises a suspicion of improper A.I. usage") | Warning | None; the court cautioned defense counsel in a footnote and denied the motion without prejudice because Lowe's did not carry its initial burden | Sep 2026 |
| Daghra v. Hinkley | W.D. Mich. U.S. District Court, Western District of Michigan, Southern Division | Jul 2026 | Unidentified (the court wrote that "it seems this citation was likely produced by generative artificial intelligence"; the order names no tool and records no explanation from the Government) | Warning | None | Sep 2026 |
| Arrieta v. Cervantes | Ariz. Ct. App. Arizona Court of Appeals, Division Two | Jul 2026 | Unidentified (the decision identifies two nonexistent cases but does not attribute them to AI) | Court sanction | Appellee Arrieta awarded her reasonable appellate attorney fees and costs as a sanction under ARCAP 25, amount to be set on compliance with ARCAP 21(b) | Sep 2026 |
| Hippe v. Retention Brands, LLC | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Jul 2026 | Unidentified (the show-cause order said hallucinated citations are "typically hallmarks of Artificial Intelligence ('AI') use" and that the motion "bears additional AI fingerprints"; counsel's response "did not specifically address" AI use and said he "utilized legal research and drafting tools to assist in the drafting process") | Other | No award of attorneys' fees and costs (plaintiff withdrew the request, which the court called "punishment enough"); "No further sanctions will be imposed" | Sep 2026 |
| In re Estate of Acciavatti (Dineen v. Kotchka) | Ariz. Ct. App. Arizona Court of Appeals, Division One | Jul 2026 | Unnamed "artificial-intelligence-assisted research tools" (the self-represented appellant's description) | Court sanction | Appellant ordered to pay the appellee the portion of her appellate attorneys' fees caused by the hallucinated and misrepresented citations (A.R.S. 12-349 and ARCAP 25), amount to be set on application; deficient citations struck and issues treated as waived | Sep 2026 |
| Jean v. Seattle Credit Union | W.D. Wash. U.S. District Court, Western District of Washington, Seattle | Jul 2026 | Unidentified (the order discharges a show-cause order over nonexistent authority, finds the plaintiff's explanations not credible, and requires future AI disclosure; it makes no finding that AI was used or which tool) | Warning | None | Sep 2026 |
| In re Rosslyn2016, LLC | Bankr. S.D. Tex. U.S. Bankruptcy Court, Southern District of Texas, Houston Division | Jul 2026 | Unidentified (the court describes the authority as 'apparently generated by artificial intelligence'; counsel said his Westlaw 'Precision' version, 'upon information and believe [sic],' incorporates AI capabilities, but attributed the citations to a prior filing or template) | Court sanction | Six hours of State Bar of Texas CLE on generative AI in the courts (the Rule 9011 sanction for the citations; non-monetary). Separately, under inherent power and 11 U.S.C. § 105(a), civil contempt of the turnover order and a bad-faith fee award to the Trustee, joint and several with the petitioning creditors (amount in the outcome) | Sep 2026 |
| Tekway, Inc. v. AT&T Services, Inc. | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Jul 2026 | Unidentified (the order flags a nonexistent citation but does not mention AI or name a tool) | Other | None | Sep 2026 |
| James F. v. Commissioner of Social Security | E.D. Mich. U.S. District Court, Eastern District of Michigan, Northern Division | Jul 2026 | Unidentified (counsel attributed the misstatements to prior work product, prior summaries, and draft language; she admitted her firm occasionally uses AI to summarize medical records but, per the order, could not be certain whether it was involved here) | Court sanction | Non-monetary Rule 11 sanction on attorney Erin Rich and her firm: four specified NOSSCR continuing legal education courses with completion report due September 14, 2026; review of pending E.D. Mich. cases for similar falsities and amendment where necessary | Sep 2026 |
| Appeal of PDO Ahuska Joint Venture LLC | ASBCA Armed Services Board of Contract Appeals | Jul 2026 | Unidentified (the Board found each of four citations "is fictitious and appears to be an AI hallucination"; no tool named) | Court sanction | Non-monetary: the fictitious citations and the contentions they supported struck from appellant's motion for partial summary judgment | Sep 2026 |
| Akerlund v. Atlas Air, Inc. | 11th Cir. U.S. Court of Appeals for the Eleventh Circuit | Jul 2026 | AI tools, not named (the Court found counsel was "outsourcing his legal work to an AI algorithm" and filed "briefs generated by AI tools") | Other | None imposed in the opinion; the Court stated that, in a separate order, it will, through the Chief Judge, refer the matter to the Committee on Lawyer Qualifications and Conduct | Sep 2026 |
| Cartagena v. Dixon | S.D.N.Y. U.S. District Court, Southern District of New York | Jul 2026 | Protégé (LexisNexis) (claimed; LexisNexis disputes Blackburn had access) | Court sanction | Not stated | Oct 2026 |
| Chapman v. Decker | S.D. Ill. U.S. District Court, Southern District of Illinois | Jul 2026 | Unidentified (the court observed that "[s]uch phenomena are becoming more frequent in the age of generative artificial intelligence" but held counsel responsible "whether these mistakes are a result of AI or other error"; it made no finding that AI was used) | Warning | None | Sep 2026 |
| Del Biaggio v. Bansen | Cal. Ct. App. California Court of Appeal, First Appellate District, Division Four | Jul 2026 | Generative AI (counsel's declaration said his office "uses generative AI"; the court gleaned from his declaration that he used it to make additions to the opening brief, and stated that he "admitted the unverified use of AI"; tool not identified) | Court sanction | $1,500 against attorney Carlton Floyd, payable to the clerk of the Court of Appeal under Cal. Rules of Court, rule 8.276(a)(4); opinion forwarded to the State Bar under Bus. & Prof. Code 6086.7(a)(3); Floyd to give his client a copy and certify he has done so; respondents' request for sanctions denied | Sep 2026 |
| Holmes v. Cape Meadows | E.D. Mo. U.S. District Court, Eastern District of Missouri, Southeastern Division | Jul 2026 | Generative AI, tool not identified (the court states the TRO motion 'appears to have been drafted using generative artificial intelligence,' citing unfilled template brackets and a nonexistent case) | Other | None | Sep 2026 |
| In re Lisa Cato | Bankr. D.D.C. U.S. Bankruptcy Court, District of Columbia | Jul 2026 | Unidentified (the order calls the citations fabricated and 'hallucinated caselaw' and cites an order requiring a generative AI certification on the filer's future filings; no tool is named) | Warning | None | Sep 2026 |
| Parnell v. Florida Department of Corrections | 11th Cir. U.S. Court of Appeals for the Eleventh Circuit | Jul 2026 | Suspected generative AI, not confirmed (the Court wrote that the citations were "generated by AI, as we suspect, or simply made up by counsel"; counsel gave no explanation) | Court sanction | Attorney's fees to the appellee for preparing the motion to strike and for sanctions (amount reserved); portions of the reply brief struck; referral of attorney Dufirstson J. Neree to the Committee on Lawyer Qualifications and Conduct | Sep 2026 |
| Burlingame v. Argo Private Client Group, Ltd. | N.D. Ohio U.S. District Court, Northern District of Ohio | Jul 2026 | Unspecified generative AI | Warning | None | Sep 2026 |
| GS Holistic, LLC v. AAR Management LLC | S.D. Tex. U.S. District Court, Southern District of Texas, Galveston Division | Jul 2026 | Unidentified (the magistrate judge wrote that he "cannot tell whether these errors are the result of shoddy work by Defendants' counsel or the use of artificial intelligence without any effort to check the citations before filing") | Warning | None; the magistrate judge called counsel's actions troubling and wrote, "I do not want to confront this issue again" | Sep 2026 |
| Patel v. Patel | W.D. Ky. U.S. District Court, Western District of Kentucky, Owensboro Division | Jul 2026 | Suspected generative AI (the show-cause order says the citations and quotations "appear to be generative artificial intelligence ('AI') hallucinations" and refers to "apparently" relying on AI-generated content); the July 7 order does not say whether counsel admitted AI use; no tool named | Warning | None; the court found the show-cause order satisfied, declined to impose sanctions, and admonished both attorneys | Sep 2026 |
| Aragon v. Industrial Claim Appeals Office | Colo. Ct. App. Colorado Court of Appeals | Jul 2026 | Unidentified (the division warned that false quotations "whether generated by an artificial intelligence tool or otherwise" in future appellate submissions may draw sanctions; it made no finding that AI was used) | Warning | None; the division declined to enter sanctions and placed counsel on notice that false quotations in future appellate submissions may result in sanctions | Sep 2026 |
| Aught v. Roe | D. Nev. U.S. District Court, District of Nevada | Jul 2026 | Suspected, not found (the court said the amended complaint "appears to be drafted with artificial intelligence"; no tool identified) | Warning | None imposed. Case-specific directive: every filing by the plaintiff must include a certification stating whether AI was used to prepare it | Sep 2026 |
| Patterson v. Nuvision Credit Union | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division Two | Jul 2026 | Unspecified AI (the court's summary of the show-cause hearing records that the self-represented appellant used an unspecified form of AI in drafting the brief and that a helper who is not currently an attorney may have relied on generative AI; tool not identified) | Court sanction | $500 sanction under Cal. Rules of Court, rule 8.276(a)(4), execution suspended; opinion forwarded to the State Bar to investigate possible unauthorized practice of law by the appellant | Sep 2026 |
| Kevin Leiske et al. v. Robert Gregory Kidd et al. | Del. Ch. Delaware Court of Chancery | Jul 2026 | Generative AI tool, not named (per the order, plaintiffs' counsel filed a letter "acknowledging the use of a generative artificial intelligence ('GenAI') tool to revise the text of the Answering Brief") | Pending | Pending | Sep 2026 |
| Carbonell v. United States | W.D. Tex. U.S. District Court, Western District of Texas, Austin Division | Jun 2026 | Unidentified (the order recounts the government's assertion that the objections contain 'hallucinated' citations 'seemingly created by the improper use of generative artificial intelligence'; the court makes no finding) | Other | None | Sep 2026 |
| P-Three Development, LLC v. Therm Flo, Inc. | Ill. App. Ct. (1st Dist.) Appellate Court of Illinois, First District, First Division | Jun 2026 | Suspected generative AI (the court had "reason to believe" the pro se intervenor "may have relied on drafting tools, such as generative AI"; not acknowledged by him; tool not identified) | Court sanction | Non-monetary: intervenor-appellant's brief stricken and appeal dismissed in the court's discretion under Illinois Supreme Court Rule 341 (the order does not describe this as a sanction) | Sep 2026 |
| Marquez v. Dreiling | D. Kan. U.S. District Court, District of Kansas | Jun 2026 | Unidentified (the order flags a quotation not found in the cited opinion but does not attribute it to AI or name a tool) | Other | None | Sep 2026 |
| Barari v. Burgess | Ariz. Ct. App. Arizona Court of Appeals, Division One | Jun 2026 | Generative AI (the court found not credible the appellant's insistence that she did not use it; she later admitted using it "only minimally"; tool not identified) | Court sanction | Non-monetary: motion to amend the opening brief denied and, as a sanction under ARCAP 25, each inaccurate and false legal citation struck; arguments deemed waived | Sep 2026 |
| Ex parte A.I.F.-H. | Ala. Civ. App. Alabama Court of Civil Appeals | Jun 2026 | Suspected AI in a dissent only (Judge Bowden wrote that four of the five cases cited in the mandamus petition "appear to be 'hallucinations' from an online artificial-intelligence ('AI') tool and misrepresentations of holdings in real cases"); the main opinion does not address it; tool not named | Other | None | Sep 2026 |
| Compania General de Combustibles S.A. v. RGR Global Logistics, LLC | S.D. Tex. U.S. District Court, Southern District of Texas, Houston Division | Jun 2026 | Unidentified (the court ordered Union Pacific to state what search engine or other tools its counsel used and said that if counsel "used artificial intelligence to aid in their legal research, they should explicitly state such"; no finding of AI use) | Pending | None imposed; show-cause directive to produce the cited case and explain how counsel located it | Sep 2026 |
| Herod v. Hobby Lobby Stores, Inc. | N.D. Tex. U.S. District Court, Northern District of Texas, Dallas Division | Jun 2026 | Generative AI, tool not named (per the order, counsel admitted at the hearing that plaintiff's counsel "failed to verify this citation after utilizing generative artificial intelligence in the drafting of his response") | Other | None; the court recorded the admission in a footnote and imposed no sanction, show-cause order, or warning | Sep 2026 |
| Landberg v. City of New York | N.Y. App. Div. 2d Dep't Supreme Court of the State of New York, Appellate Division, Second Department | Jun 2026 | Unnamed free, publicly available AI-assisted research tool (counsel's affirmation: "one of the free ones available to the public") | Court sanction | $8,000 against attorney Michael Sanders and $2,500 against Law Offices of Michael S. Lamonsoff, PLLC, each payable to the Lawyers' Fund for Client Protection within 20 days of service | Sep 2026 |
| Patterson v. Digital Federal Credit Union | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division Two | Jun 2026 | Unidentified (the court states the citation errors "bear the hallmarks of fabricated legal authority created by generative artificial intelligence (AI)"; no finding or admission of AI use, no tool named) | Other | None: arguments resting on nonexistent cases and quotations deemed forfeited; judgment affirmed with costs to respondent; trial court directed to hold a noticed hearing on whether to declare the appellant a vexatious litigant | Sep 2026 |
| Euphoric, LLC v. Westport Community Improvement District | W.D. Mo. U.S. District Court, Western District of Missouri, Western Division | Jun 2026 | Unidentified (neither order finds AI use; the June 3, 2026 order said counsel's duty applies "whatever the root cause for these inaccuracies and errors (including any use of legal or non-legal generative AI tools, for example)"; the June 22 show-cause order does not mention AI) | Pending | None yet; show-cause order under Rule 11, 28 U.S.C. 1927, and the court's inherent authority, requiring a declaration and a response brief by July 8, 2026 | Sep 2026 |
| FHMC, LLC v. Blue Cross and Blue Shield of Arizona, Inc. | Ariz. Ct. App. Arizona Court of Appeals, Division One | Jun 2026 | Unidentified (the decision flags fabricated LexisNexis reporter citations and unsupported propositions but does not attribute them to AI) | Other | No monetary sanction; decision forwarded to the State Bar of Arizona to review whether counsel violated any rule of professional conduct | Sep 2026 |
| Hoagland Family Limited Partnership v. Town of Clear Lake | Ind. Ct. App. Court of Appeals of Indiana | Jun 2026 | Unidentified (the court says it is "likely" the nonexistent citation and quotation "were created using generative artificial intelligence"; no tool is named and the opinion records no explanation in the reply brief) | Warning | None | Sep 2026 |
| Zhdanovich-Doty v. Provident Life and Accident Insurance Company | N.D. Cal. U.S. District Court, Northern District of California | Jun 2026 | Suspected, no tool named (the court states it "is concerned that plaintiff's counsel relied on an artificial intelligence tool that generated a nonexistent case citation"; no finding or admission) | Warning | None; counsel was placed "on notice that any future submission of nonexistent authority may result in appropriate sanctions" | Sep 2026 |
| House v. TH Foods, Inc. | D. Nev. U.S. District Court, District of Nevada | Jun 2026 | Unidentified (the order recounts that at a November 17, 2025 hearing the court noted the plaintiff 'appeared to be relying on artificial intelligence to draft his filings'; no tool is named) | Pending | Pending | Sep 2026 |
| Progressive Northern Insurance Company v. Tony Pete Flores, et al. | D. Nev. U.S. District Court, District of Nevada | Jun 2026 | Unidentified (the order describes "Counsel's submission of AI-generated content without verifying the accuracy of the cited authorities"; no tool is named) | Warning | None | Sep 2026 |
| Twigg v. BSN Sports, Inc. | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Jun 2026 | Unidentified (the May 21, 2026 opinion refers to "the usage of what appears to be artificial intelligence in the brief" and says counsel "tacitly admitted that the errors were due to the use of artificial intelligence"; no tool named) | Court sanction | $1,500 payable personally by Nicholas W. Mattiacci, Sr. to the Clerk of Court within 14 days (not counted toward taxed litigation costs); six-month suspension from practicing in the Middle District of Pennsylvania, with automatic reinstatement, commencing June 22, 2026 | Sep 2026 |
| Barber v. Morawa | Mich. Ct. App. Michigan Court of Appeals | Jun 2026 | AI research tools, not named (counsel's Notice of Correction attributed the errors to "over-reliance on artificial intelligence research tools"; at oral argument he acknowledged using AI to prepare the Notice itself) | Court sanction | Defendant's actual damages and expenses, including reasonable attorney fees, incurred because of the vexatious appeal, to be determined by the trial court after an evidentiary hearing on remand and paid by plaintiff's counsel personally; opinion forwarded to the Attorney Grievance Commission | Sep 2026 |
| Ajakaiye v. Oladipupo | Md. App. Ct. Appellate Court of Maryland | Jun 2026 | Unidentified (counsel denied using AI; the court found he copied citations from the client's pro se filing and said copying from filings "generated using AI--which is likely what happened here" is no less problematic) | Other | No monetary sanction; matter referred to the Attorney Grievance Commission | Sep 2026 |
| Jacob Doe v. The University of North Carolina System, et al. | W.D.N.C. U.S. District Court, Western District of North Carolina, Asheville Division | Jun 2026 | Unidentified (the show-cause order said some citations "might constitute AI hallucinations"; the discharge order recounts that counsel attributed the errors "in large part" to "misuse of artificial intelligence software" and a failure to verify its outputs; no tool is named) | Other | None | Sep 2026 |
| Hayes v. Miller | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District | Jun 2026 | Unidentified (the opinion notes "several citations to nonexistent cases" in a trial-court filing but does not mention artificial intelligence or name a tool) | Other | None; the court noted the citations in a footnote and took no action on them | Oct 2026 |
| Holstein v. Holstein | Ind. Ct. App. Court of Appeals of Indiana | Jun 2026 | Unidentified (counsel told the court his client supplied the citations; the opinion warns about the risks of AI and quotes commentary on AI-sourced authority but does not find that AI produced them) | Other | None | Sep 2026 |
| Matter of OS-DB-JV-2, LLC | GAO U.S. Government Accountability Office | Jun 2026 | Unidentified (GAO says the erroneous citations "bear the hallmarks of the use of a large-language model or other artificial intelligence (AI)"; the protester attributed them to software tools used to support research; no tool is named) | Warning | None | Sep 2026 |
| K.W. v. Ringwood Board of Education | D.N.J. U.S. District Court, District of New Jersey | Jun 2026 | Unidentified (the court ordered counsel to disclose whether he used generative AI; the opinions do not report his answer or find AI use, and the June 16 caution quotes a case on "AI hallucinated case law") | Warning | None | Sep 2026 |
| Amazon.com Inc. v. Hao | W.D. Wash. U.S. District Court, Western District of Washington, at Seattle | Jun 2026 | AI-assisted research, no tool named (the order records that Hao "relied in part on artificial-intelligence-assisted research, along with Westlaw and other research platforms") | Court sanction | No monetary sanction; the court struck the motion to dismiss without prejudice to refiling, declined "at this time" to impose monetary sanctions, and warned of future sanctions | Sep 2026 |
| Merz v. Jenkins | Wash. Ct. App. Washington Court of Appeals, Division One | Jun 2026 | Unidentified (the opinion flags a nonexistent quotation and misused authorities but does not attribute them to AI or name a tool) | Other | None | Sep 2026 |
| Quinteros v. Harbor Distributing, LLC | Cal. Ct. App. California Court of Appeal, First Appellate District, Division Two | Jun 2026 | Generative AI (the trial court's sanctions order found the contract attorney who drafted the brief "evidently utilize[d] generative AI" and "denied under oath having done so"; his declaration said he used Lexis and Lexis Protégé; tool not otherwise identified) | Court sanction | Trial court sanction affirmed: $6,000 jointly and severally against Lipeles Law Group, APC and attorneys Kevin Lipeles, Thomas Schelly, and Jasmine Badawi ($5,000 to defendants, $1,000 to the court) under Code Civ. Proc. 128.7, plus service of the order on the client, the judge in a related Los Angeles action, and San Francisco judges for one year | Sep 2026 |
| Villanueva v. Bowers | Ariz. Ct. App. Arizona Court of Appeals, Division One | Jun 2026 | Generative AI (the self-represented appellant "confessed she used generative artificial intelligence to produce her briefs"; tool not identified) | Court sanction | Appellee awarded his reasonable appellate attorney fees and costs under A.R.S. 25-324 and ARCAP 25, amount to be set on compliance with ARCAP 21; appellant's own fee request denied | Sep 2026 |
| Henry County Schools v. Grant | Ga. Ct. App. Court of Appeals of Georgia, First Division | Jun 2026 | Implied, not found (the court says the trial court's order, drafted by the plaintiffs' attorney, "relies on at least one hallucinated case" and reminds counsel of their obligations "in the use of artificial intelligence"; it names no tool and makes no finding that AI was used) | Warning | None | Sep 2026 |
| Obi v. Cook County, Illinois | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Jun 2026 | Generative AI, tool not identified (the court states that the plaintiff 'continues to submit AI hallucinated arguments and cases' and has 'continually filed briefs generated by AI') | Warning | None | Sep 2026 |
| LiveVideo.AI Corp v. Redstone | S.D.N.Y. U.S. District Court, Southern District of New York | Jun 2026 | Generative AI, tool not identified (the court states that each struck motion 'appears to have been drafted by AI' and that nearly all motions in the matter bear 'the hallmarks of artificial intelligence ("AI") fabrication') | Court sanction | $85,056 in attorneys' fees and costs, ordered paid by plaintiff LiveVideo.AI Corp and its counsel Alfred Camillo Constants, III, under 28 U.S.C. § 1927 and inherent power; Constants again referred to the S.D.N.Y. Grievance Committee | Sep 2026 |
| Nunez v. American Airlines, Inc. | S.D. Fla. U.S. District Court, Southern District of Florida | Jun 2026 | Unidentified (the R&R finds the two cases do not exist and quotes O'Brien v. Flick on fake authority "generated by artificial intelligence programs," but does not find that Nunez used AI) | Court sanction | None monetary; the adopted R&R recommends dismissal with prejudice as a sanction, and the district judge's order dismisses with prejudice on Montreal Convention futility grounds | Sep 2026 |
| State v. Stroup | Mont. Montana Supreme Court (describing orders of the Fourth Judicial District Court, Missoula County) | Jun 2026 | Unidentified (the order describes the filing as one Stroup implies was prepared with generative AI without the required disclosure; no tool is named) | Court sanction | Not stated | Oct 2026 |
| Tlingit Haida Tribal Business Corporation v. OnePromom, LLC | D. Colo. U.S. District Court, District of Colorado | Jun 2026 | Eve Legal (named in defense counsel's own AI certification in the motion, as quoted by the court: "generative artificial intelligence--specifically, Eve Legal--was used to draft this filing"; the court does not find that the tool produced the misattributed quotation) | Pending | None imposed in this order; order to show cause, response due June 23, 2026, why defense counsel Marianna McLean should not be sanctioned under Rule 11 and/or "the Court's inherent authority under 28 U.S.C. § 1927" (as printed) | Sep 2026 |
| Williams v. Rashid | D. Nev. U.S. District Court, District of Nevada | Jun 2026 | Unnamed AI (counsel's errata acknowledged that the "errors are the result of using AI for research and drafting assistance ..."; the order states that local counsel Jason Guinasso "admits he used AI"; no tool is named) | Court sanction | Defendant Las Vegas Bistro's reasonable attorney's fees and costs attributable to the AI hallucinations, jointly and severally against the National Center on Sexual Exploitation and Guinasso Law, Ltd., amount to be agreed or set on motion; amended filings struck and the reconsideration motion denied with prejudice, in part as sanctions | Sep 2026 |
| Bailey v. Sedgwick Claims Management Services, Inc. | W.D. Tenn. U.S. District Court, Western District of Tennessee, Western Division | Jun 2026 | Unnamed "AI tool" (per the order, plaintiff's counsel "agreed that these errors were most likely the result of the AI tool"; the court wrote "Apparently that AI program hallucinated over some citations") | Other | None (sanctions declined; counsel required to correct the citations and file a corrected motion) | Sep 2026 |
| Withers v. City of Aberdeen | N.D. Miss. U.S. District Court, Northern District of Mississippi, Aberdeen Division | Jun 2026 | Plaintiff's counsel: "First Drafts" (AI drafting program); defense counsel: an unnamed AI legal-research product her firm acquired | Court sanction | $8,000 total in fines to the court registry: Wilson $2,500 (plus AI-ethics CLE), Williams $3,500, Ridgeway $1,000, McClinton $1,000; pro hac vice revoked and two-year N.D. Miss. appearance bar for Wilson and Williams; local counsel disqualified; copies to the Mississippi, Louisiana, and Texas bars | Sep 2026 |
| Owens v. Select Portfolio Servicing, Inc. | E.D.N.Y. U.S. District Court, Eastern District of New York | Jun 2026 | Suspected, not found (the court wrote that the citation issues "suggest that the plaintiff is relying on artificial intelligence" for research or drafting without confirming its accuracy; no finding of AI use and no tool named) | Warning | None (warning that the court "will impose sanctions for any further violations, including summary dismissal of his claims") | Sep 2026 |
| Witkin v. McGreevy | Or. Sup. Ct. Supreme Court of Oregon | Jun 2026 | Generative AI, tool not named (the order recounts that his show-cause response explained that he "had used generative artificial intelligence" to create the pleading) | Court sanction | $500 payable to the Appellate Court Services Division (stipulated); response to the petition for review stricken | Sep 2026 |
| Lnu v. Blanche | 9th Cir. U.S. Court of Appeals for the Ninth Circuit | Jun 2026 | Generative AI (counsel conceded AI use by the firm's unlicensed brief writers was "more likely than not"; tool not identified) | Court sanction | $5,000 total ($2,500 each against attorneys Mike Singh Sethi and William Rounds); six-month suspension of both from practice before the Ninth Circuit; notice to clients, courts, and firm attorneys; two-year sworn AI-disclosure certification on all future filings by every attorney at the firm; referral to the State Bar of California | Sep 2026 |
| Boatner v. Hickerson | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District | Jun 2026 | Unidentified AI (appellant 'conceded at oral argument she used A.I. to draft parts of her brief'; the court found four cited cases fictitious; tool not named) | Court sanction | $10,000 in damages under Rule 84.19 for a frivolous appeal, entered as a judgment against the appellant in favor of the respondent (for appellate attorney's fees) | Sep 2026 |
| El Bitar v. Hernandez | W.D. Wash. U.S. District Court, Western District of Washington, Tacoma | Jun 2026 | Google Gemini (per drafting counsel's sworn declaration, used by legal interns who researched the filings) | Court sanction | $1,000 personal sanction on drafting attorney Julian Mansoor Daman, payable to the Clerk within 21 days, with a public reprimand; reprimand, without a fine, of local counsel Jennifer Nimer | Sep 2026 |
| Grajales v. Santander Consumer USA Inc. | M.D.N.C. U.S. District Court, Middle District of North Carolina | Jun 2026 | Suspected generative AI, tool not named (the court: "it appears Plaintiff has also been using some form of generative artificial intelligence resulting in citations which are hallucinations or other improper citations") | Court sanction | $120 penalty to the Clerk; case stayed 90 days or until paid; plaintiff must attach copies of all cited law to future pleadings or they will be struck | Sep 2026 |
| Reaves Law Firm, PLLC v. Baker, Donelson, Bearman, Caldwell & Berkowitz, PC | W.D. Tenn. U.S. District Court, Western District of Tennessee, Western Division | Jun 2026 | Generative AI, tool not named (the court sanctions the firm's "improper and insufficiently explained use of AI"; the firm, apart from a fleeting reference to an internal AI-policy email, did not acknowledge that AI had any role) | Court sanction | Reimbursement of defendants' fees for four responsive filings (set at $45,763 by the July 10, 2026 fee order, joint and several with Henry Reaves III); order forwarded to the district's other judges and to Tennessee disciplinary counsel | Sep 2026 |
| Perez-Castillo v. Blanche | 7th Cir. U.S. Court of Appeals for the Seventh Circuit | Jun 2026 | ChatGPT, per the drafting attorney (Farah Chalisa said she "used ChatGPT to perform the copyediting tasks necessary" and not for legal research, while hinting at using "any system incorporated into Lexis/Nexis"; the Court found the brief "riddled with AI hallucinations" and doubted her grammar-check account) | Court sanction | $5,000 fine against attorney Abdullah Salah under Fed. R. App. P. 46(c); attorney Farah Chalisa admonished; matter referred to the Illinois Attorney Registration and Disciplinary Commission; show-cause order kept open pending ARDC review; no sanction on Chalisa "at this time" | Sep 2026 |
| Sharei Torah v. Hendel | N.Y. Sup. Ct. Supreme Court of the State of New York, Queens County (Commercial Division) | Jun 2026 | Unidentified (the court said the defects "appear to be exemplary of the result of using artificial intelligence-based tools"; the defendant denied using AI) | Court sanction | Defendant Mendel Hendel's amended answer struck and default entered for fraud on the court; Hendel to reimburse plaintiff's legal fees for four NYSCEF filings responding to his notice of removal, amount to be fixed on submission | Sep 2026 |
| H. C. v. Contreras | Cal. Ct. App. California Court of Appeal, Fifth Appellate District | May 2026 | Unidentified (the opinion calls the cited case "fictitious" and "nonexistent" but does not attribute it to AI or name a tool) | Other | None; the opinion quotes counsel's duties of candor from a prior decision but imposes no sanction on counsel and does not mention a referral | Sep 2026 |
| In re M.H., M.L., and M.H., Minors | Ill. App. Ct. (1st Dist.) Appellate Court of Illinois, First District, Fourth Division | May 2026 | Not mentioned in the order (the court describes the Public Guardian's objection that the brief references "cases that do not exist"; it does not attribute the inaccuracies to AI) | Pending | None imposed in the May 28, 2026 order; a rule to show cause was issued to the Mother's counsel, with any sanction to follow in a separate written order | Sep 2026 |
| United States ex rel. Solano v. Barton Associates, Inc. | 1st Cir. U.S. Court of Appeals for the First Circuit | May 2026 | Unidentified (the opinion states that the relators' briefs quoted language that does not appear in the cited cases "or in any case that we have been able to find" but does not attribute it to AI or name a tool) | Other | None; the court noted the defects in the text and a footnote and took no action on them | Sep 2026 |
| Avery v. Beauzil | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | May 2026 | Unidentified AI service (the court described the petitions, supplements, and show-cause response as AI-generated, e.g. the first petition "was generated using artificial intelligence (AI)"; the petitioner said he pays "$20/month" for his AI service; no tool named) | Court sanction | Non-monetary: the Clerk is directed to reject any future filings by the petitioner unless signed by a member in good standing of The Florida Bar; by separate order, counsel required in his other pending Fourth DCA cases or those cases will be dismissed | Sep 2026 |
| Eclectic Synergy, LLC v. Seredin | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | May 2026 | Unidentified (the court's show-cause order said the petition "appears AI-generated"; counsel did not acknowledge using AI and blamed a paralegal and a "transcription error"; the court held that "whether counsel used AI makes no difference") | Court sanction | Non-monetary: referral of the matter to The Florida Bar for appropriate action ("counsel sanctioned with referral to The Florida Bar") | Sep 2026 |
| Innocent v. Meraki Installers, LLC | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | May 2026 | Unidentified (the opinion flags trial-transcript quotations that do not appear in the record but does not mention AI or name a tool) | Other | No monetary sanction; matter referred to The Florida Bar for appropriate action | Sep 2026 |
| Matter of Julien v. Arthur | N.Y. App. Div. 2d Dep't Supreme Court of the State of New York, Appellate Division, Second Department | May 2026 | Generative AI (tool not named; the court found the brief "highly suggestive of having been created with the aid of GenAI" and the father acknowledged relying on research tools and an internet source) | Court sanction | $250 under 22 NYCRR 130-1.1(c)(1), deposited with the Clerk for transmittal to the Commissioner of Taxation and Finance (see 22 NYCRR 130-1.3), with a caution that future GenAI misuse may result in a greater sanction | Sep 2026 |
| State of Oklahoma ex rel. Oklahoma Bar Association v. Reeves | Okla. Sup. Ct. Supreme Court of Oklahoma | May 2026 | ChatGPT (respondent "admitted he used the generative artificial intelligence (AI) known as ChatGPT to obtain five citations") | Bar discipline | Public reprimand (reciprocal discipline) | Sep 2026 |
| Williamson v. Meyers | D. Del. U.S. District Court, District of Delaware | May 2026 | Unidentified (per the opinion, Plaintiff conceded the fictitious citation "was most likely the result of artificial intelligence"; no tool named) | Other | None | Sep 2026 |
| Adams v. 3M Company | N.D. Ala. U.S. District Court, Northern District of Alabama, Middle Division | May 2026 | Generative AI (per the court, counsel admitted using generative AI; her response attributes the errors to "AI-assisted research and summary tools"; no tool is named) | Court sanction | Public reprimand only (no monetary sanction), with a warning that future misuse of AI before any judge in the district "will likely result in severe sanctions" | Sep 2026 |
| Guo v. Meade Motorcars, LLC | Ohio Ct. App. (6th Dist.) Court of Appeals of Ohio, Sixth Appellate District (Sandusky County) | May 2026 | Deepseek (the appellant's own explanation on appeal, as recounted by the court; the court found the citations "appear to be the result of AI-generated hallucinations") | Court sanction | $100 (imposed by the Sandusky County Court of Common Pleas on Aug. 11, 2025; the court of appeals affirmed the denial of the motion to vacate it) | Sep 2026 |
| In re M.A.L.B. | Ohio Ct. App. (4th Dist.) Ohio Court of Appeals, Fourth Appellate District (Washington County) | May 2026 | Suspected, unidentified (the court states in a footnote: "We suspect that the problems with appellant's citations stem from the unverified use of artificial intelligence"; no tool named) | Court sanction | Non-monetary: appeal dismissed for failure to file a conforming brief after the original brief was struck; costs assessed to appellant | Sep 2026 |
| Kalonji v. State | Ind. Ct. App. Court of Appeals of Indiana | May 2026 | Generative AI suspected, tool not identified (the court said it is "likely that Kalonji used generative artificial intelligence (AI) to draft his briefs, either in whole or in part") | Warning | None | Sep 2026 |
| Maxwell v. Michael | S.D. Ind. U.S. District Court, Southern District of Indiana, Indianapolis Division | May 2026 | Suspected, not admitted (the court agreed with the defendants that the fabricated authority "contains the hallmarks of generative AI hallucinations"; the plaintiff's response did not confirm AI use) | Court sanction | $1,000 Rule 11 sanction payable to the Clerk by June 25, 2026 (plus a separate $886.80 in deposition costs owed to the defendants on an earlier discovery sanction) | Sep 2026 |
| Fuselier v. RisCassi | S.D. Miss. U.S. District Court, Southern District of Mississippi, Southern Division | May 2026 | Possibly a search engine's AI preview (counsel said he found the citation through Google web searches and was "not certain it came from the AI preview"; the court wrote that "in the Court's view it is hard to see what else would have generated the fake case") | Warning | None | Sep 2026 |
| In re the Marriage of Amy Haddock and Justin Blu Haddock | Okla. Dist. Ct. (Tulsa Cnty.) District Court of Tulsa County, Oklahoma | May 2026 | Unidentified (the order finds citations to nonexistent law and inaccurate case descriptions but does not mention AI) | Court sanction | $2,000 sanction against attorney N. Scott Johnson, payable into the court fund within thirty days of the order's recited April 1, 2026 hearing date (the order was filed May 21, 2026); son's motion for fees sustained with the amount and liable parties set for a May 20, 2026 hearing; firm asked to audit its case bank, with McCord to report on the audit; order to be reported to the Oklahoma Bar Association | Sep 2026 |
| Downing v. Brown | 11th Cir. U.S. Court of Appeals for the Eleventh Circuit | May 2026 | Unidentified (the opinion calls the authorities "fabricated" and "fictitious" but does not mention AI or any tool) | Court sanction | No monetary sanction; portions of the appellant's brief containing fabricated legal authorities struck as improper | Sep 2026 |
| Sherwood v. County of Botetourt, Virginia | W.D. Va. U.S. District Court, Western District of Virginia, Roanoke Division | May 2026 | Suspected generative AI (the opinion says the claims "include citations to hallucinated law ostensibly obtained from generative AI tools" and that the court "cannot account for" one miscitation "beyond the use of generative AI"; counsel gave no satisfactory answer when asked at the hearing whether the citations came from an AI tool; no tool named) | Other | None imposed; leave to file a second amended complaint denied on the ground that it was sought in bad faith | Sep 2026 |
| Chakma v. Sushi Katsuei, Inc. | S.D.N.Y. U.S. District Court, Southern District of New York | May 2026 | LexisNexis AI tool (defense counsel "acknowledged that she had used LexisNexis's AI tool to help construct multiple submissions to the Court") | Court sanction | Against defense counsel for the AI-generated false submissions: $1,710 of class counsel's fees plus a $1,000 penalty payable to the Clerk | Sep 2026 |
| McNeal v. Calvin | E.D. Mo. U.S. District Court, Eastern District of Missouri, Eastern Division | May 2026 | Unidentified (neither the show-cause order nor the sanctions order mentions AI; the plaintiff said she relied on "widely accepted legal research platforms, including LexisNexis") | Court sanction | Non-monetary Rule 11 sanction: every future filing in the case must attach a sworn declaration that the plaintiff personally researched each citation to confirm it exists and is accurately characterized (filings without one to be stricken); defendants ordered not to respond to her filings unless the court explicitly orders a response | Sep 2026 |
| [Petitioner name redacted] v. United States Citizenship and Immigration Services | D. Or. U.S. District Court, District of Oregon | May 2026 | Unidentified (the court states that two filings by USCIS's counsel "contained hallucinated case citations"; it does not say how they were produced or name a tool) | Other | None; the court allowed USCIS to file amended versions of the two filings | Sep 2026 |
| Brooks v. Lowes Home Centers LLC | W.D. La. U.S. District Court, Western District of Louisiana, Alexandria Division | May 2026 | Claude (the court recounts that Wilkins "utilized an artificial intelligence (“AI”) platform, Claude, to generate the brief") | Court sanction | $1,000 against W. Paul Wilkins personally (not payable by his firm), due June 12, 2026; three hours of CLE on AI-assisted legal practice before December 31, 2026 | Sep 2026 |
| Glenn Wilder and Others v. President & Fellows of Harvard College and Others | Mass. Super. Ct. Massachusetts Superior Court, Suffolk County | May 2026 | MX2.law, Morgan & Morgan's in-house AI platform (used in the earlier Wyoming federal case the order relies on; no AI use alleged in this Massachusetts case) | Other | None; pro hac vice admission of T. Michael Morgan denied | Sep 2026 |
| Waggeh v. Utility Workers Union of America Local 1-2 | S.D.N.Y. U.S. District Court, Southern District of New York | May 2026 | Unidentified (the order finds the cited cases do not stand for the propositions cited and that counsel violated Rule 11; it does not mention AI or name a tool) | Court sanction | Non-monetary Rule 11 sanction: public admonishment of petitioner's counsel | Sep 2026 |
| Matter of Janelle Melissa Lewis | N.Y. App. Div. 1st Dep't New York Supreme Court, Appellate Division, First Department | May 2026 | ChatGPT or a similar AI program, as attributed by the federal court (this order recites that the court attributed the non-existent cases to "hallucinations by ChatGPT or a similar artificial intelligence program"; the D.N.M. order itself says the cases were "likely the handiwork of a ChatGPT or similar artificial intelligence (AI) program's hallucinations"); the suspension rests on non-cooperation with the disciplinary investigation | Bar discipline | Interim suspension from the practice of law in New York, effective immediately and until further order of the court (22 NYCRR 1240.9(a)(3)) | Sep 2026 |
| Jane Doe 1 v. Mount Saint Mary High School Corporation of the State of Oklahoma | W.D. Okla. U.S. District Court, Western District of Oklahoma | May 2026 | Unnamed AI tools (counsel "acknowledged that she used AI tools without performing the essential step of personally reviewing the cited authority") | Court sanction | Non-monetary: public reprimand; copy of the order to each client with a filed certification; self-report with a copy of the order to the state bar authority where licensed (no fine, in light of a same-day Rule 37 fee award and the monetary sanction imposed the same day in Crist v. West) | Sep 2026 |
| Guy v. American Federation of Government Employees, AFL-CIO | N.D. Cal. U.S. District Court, Northern District of California | May 2026 | Claude Console, per counsel's sworn declaration filed in response to the order ("I used an enterprise level, data-isolated AI platform, Claude Console, to create an initial draft of the motion"); the order itself calls the quotations "hallucinated" and "fabricated" but names no tool | Other | None imposed; counsel ordered to file a declaration under penalty of perjury explaining the fabricated case quotations | Sep 2026 |
| In re Latasha Transrina Kebe | Bankr. S.D. Fla. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division | May 2026 | Unidentified (the orders address citation errors that debtor's counsel acknowledged, but do not attribute them to AI or name a tool) | Court sanction | Bankruptcy Rule 9011 sanction against Chad T. Van Horn, Esq. and Van Horn Law Group, P.A., jointly and severally, equal to 10% of the creditor's fees for the reply brief; fixed at $2,231.84 by the June 30, 2026 agreed order, payable to the creditor | Sep 2026 |
| Drip Capital, Inc. v. SGM Socher Inc. | N.Y. Sup. Ct. Supreme Court of the State of New York, New York County | May 2026 | Unidentified (the court's May 12 order sanctions counsel "for citing two AI hallucinated cases in the opposition brief"; its May 1 decision had said the brief included "what appear to be AI hallucinations"; no tool is named) | Court sanction | $1,000 to the Lawyers' Fund for Client Protection under 22 NYCRR 130-1.1, against defense counsel Alexander Levkovich, with an affirmation of compliance, originally due May 20, 2026 and extended to June 30, 2026 (reduced from the $3,000 proposed in the show-cause directive; a request to reduce or vacate it further was denied) | Sep 2026 |
| Gully v. Varghese | N.Y. Sup. Ct. Supreme Court of the State of New York, Albany County | May 2026 | Unidentified (the court found the cited cases "appear to be 'hallucinations' created by an artificial intelligence tool"; no tool named) | Court sanction | Non-monetary: plaintiff's summary judgment motion denied and the submissions containing the false citations struck; no fine | Sep 2026 |
| Jacobs v. Timberlake | La. App. 5 Cir. Court of Appeal of Louisiana, Fifth Circuit | May 2026 | Not determined (the court ordered counsel to address "whether any generative artificial intelligence tool was used" in preparing the writ application; the order makes no finding of AI use and names no tool) | Pending | None imposed in the May 12, 2026 order; rule to show cause, by brief, why relator's counsel should not be held in contempt under La. C.C.P. art. 224(4) | Sep 2026 |
| Morales Jimenez v. Shanahan | E.D.N.Y. U.S. District Court, Eastern District of New York | May 2026 | Unidentified (the decision does not mention artificial intelligence; it states that petitioner's counsel relied on "at least one nonexistent case") | Other | None; the court criticized counsel's briefing in its decision but imposed no sanction and issued no warning | Sep 2026 |
| Shore v. Dorel Juvenile Group, Inc. | D. Mass. U.S. District Court, District of Massachusetts | May 2026 | ChatGPT and Claude (the order states that attorney Kevin Laukaitis used AI tools, "ChatGPT and Claude," to finalize the brief, citing counsel's show-cause filing, Doc. No. 32-1) | Court sanction | $2,500 payable by attorney Kevin Laukaitis to the defendant; plaintiffs' opposition brief struck with leave to refile; Laukaitis Law LLC ordered to file a status report within 21 days stating whether it has implemented the court's suggested procedures or similar measures | Sep 2026 |
| Armstrong v. City of Milwaukee | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | May 2026 | Unidentified (the order notes a fictitious case in the County's original reply brief but says the court "does not have more information as to why that happened"; it does not mention AI) | Other | None | Sep 2026 |
| Burches v. Equifax Information Services, LLC | E.D. La. U.S. District Court, Eastern District of Louisiana | May 2026 | AI, tool not named (the court's May 20, 2026 order states "Plaintiff again improperly used AI while preparing his filings"; the May 11 sanction order itself does not mention AI) | Court sanction | $500 payable to the Clerk of Court by June 10, 2026 | Sep 2026 |
| DeVore v. McCombie | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | May 2026 | Unidentified (the order does not mention artificial intelligence; it directs defense counsel to explain how the memorandum "was generated") | Other | None; defense counsel ordered to file a declaration explaining how the memorandum was generated and how counsel located the two authorities | Sep 2026 |
| Crist v. West | W.D. Okla. U.S. District Court, Western District of Oklahoma | May 2026 | A "trusted legal vendor's AI tool" (counsel's own description, as quoted by the court; the tool is not named) | Court sanction | $250 to the Clerk of Court for the general court fund; public reprimand; copy of the order to the client with a filed certification | Sep 2026 |
| Fivehouse v. U.S. Department of Defense | E.D.N.C. U.S. District Court, Eastern District of North Carolina, Northern Division | May 2026 | Unnamed generative AI tool (admitted by the attorney only under the court's questioning at the show-cause hearing) | Court sanction | Non-monetary: public reprimand of former Assistant United States Attorney Rudy E. Renfer; opinion submitted for publication; no financial penalty | Sep 2026 |
| Harris v. Pinnacle Bank | N.D. Miss. U.S. District Court, Northern District of Mississippi, Oxford Division | May 2026 | Generative AI, tool not named (the plaintiff "admitted that he had submitted incorrect, fictitious, and AI-generated legal citations to the Court on numerous separate occasions") | Court sanction | Dismissal of all claims with prejudice; defendant permitted to move for fees and costs within fourteen days | Sep 2026 |
| In re Marriage of Nash | Colo. Ct. App. Colorado Court of Appeals | May 2026 | Unidentified (the court observed that the father's citations of nonexistent cases "bear many of the hallmarks of 'hallucinations'" associated with generative AI; no tool named) | Court sanction | $1,665 attorney fee award under C.R.S. 13-17-102 (entered by the district court Apr. 14, 2025; affirmed). Separately, and not as a sanction, the Court of Appeals awarded the mother appellate attorney fees and costs under C.A.R. 39.1 and 39(c)(1) because she successfully defended the fee awards; amount to be set on remand | Sep 2026 |
| Song Dow Lee v. HSBC Bank USA, National Association | C.D. Cal. U.S. District Court, Central District of California | May 2026 | Not determined (the order to show cause directs counsel's declarations to address "whether artificial intelligence was used"; the order makes no finding of AI use and names no tool) | Other | None imposed in the May 7, 2026 order; counsel ordered to show cause why the court should not impose sanctions of $2,500.00 on counsel and/or dismiss the action | Sep 2026 |
| Stokka v. Stokka | N.D. Sup. Ct. Supreme Court of North Dakota | May 2026 | Unidentified (the opinion calls the authorities in the brief "irrelevant, fictitious, or nonexistent" and cites City of Dickinson v. Helgeson as explaining that fake citations typically result from AI hallucinations, but makes no finding that the appellant used AI) | Court sanction | Fixed award of $1,000 in double costs and attorney's fees to the appellee (not labeled a sanction in the opinion) | Sep 2026 |
| Boersma v. Davenport | Or. Ct. App. Oregon Court of Appeals | May 2026 | Unidentified (the opinion flags fabricated and inapposite case citations but does not attribute them to AI or name a tool) | Court sanction | $500, payable to the Appellate Court Services Division of the Oregon Judicial Department | Sep 2026 |
| Gregoire v. San Francisco Bay Area Rapid Transit District | N.D. Cal. U.S. District Court, Northern District of California | May 2026 | Suspected generative AI, not confirmed (the court was concerned the missing cases "suggest hallucinations from the use of generative artificial intelligence tools"; counsel did not respond, and no tool is identified) | Court sanction | $1,000 personal sanction payable to the Clerk; service of the order on the client; at least one hour of CLE on the ethical use of AI; order served on the State Bar of California | Sep 2026 |
| Robinson v. Davidson County | N.C. Ct. App. North Carolina Court of Appeals | May 2026 | Suspected (the court said its concerns with the brief "raise the question of whether this brief was generated, at least in part, by artificial intelligence"; no finding or admission of AI use, no tool named) | Warning | None; the court reminded appellate counsel that "[f]ailure to follow the rules is sanctionable" | Sep 2026 |
| Doe v. The Trustees of Columbia University in the City of New York | N.Y. Sup. Ct. Supreme Court of the State of New York, New York County | May 2026 | Unidentified AI (the court refers to "AI-generated hallucinations" in the petitioners' papers, and counsel acknowledged at oral argument that using AI without proper checking was wrong; no tool is named) | Other | None | Sep 2026 |
| Fuller v. Hyde School | D. Me. U.S. District Court, District of Maine | May 2026 | Claude or ChatGPT (counsel disclosed, only in her show-cause response, that she or someone on her team used AI, "either Claude or ChatGPT," in drafting) | Court sanction | Non-monetary: admonition; CLE on generative AI with proof of attendance; firm procedures to prevent recurrence, explained in a certification; copy of the order to the client; certification of compliance within 45 days (the opposition brief was also struck) | Sep 2026 |
| Payne v. State | Ga. Sup. Ct. Supreme Court of Georgia | May 2026 | Unnamed "artificial intelligence software" (the assistant district attorney acknowledged using it to draft the State's briefs opposing the motion for new trial and the proposed order; the opinion does not name the tool) | Court sanction | Six-month suspension of ADA Deborah Leslie's privilege to practice before the Supreme Court of Georgia, with reinstatement conditioned on 12 additional CLE hours (ethics, brief writing, proper use of AI software) and a petition for reinstatement; admonishment of ADA Leslie and the Clayton County district attorney's office | Sep 2026 |
| Van Deel v. A-Plus Contracting, LLC | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District | May 2026 | Unidentified (the opinion notes "multiple inaccurate or nonexistent caselaw citations" in appellant's brief but does not mention artificial intelligence or name a tool) | Other | None; the court noted the citations in footnotes and dismissed the appeal under Rules 84.04 and 74.04(c) on other briefing grounds | Oct 2026 |
| Carter v. UZGlobal LLC | D.N.M. U.S. District Court, District of New Mexico | May 2026 | Unidentified AI program (plaintiffs' counsel believed a now-terminated associate used AI but did not know which program) | Court sanction | $1,000 fine to the Clerk of Court; self-report to the Texas disciplinary authority and copy of the order to the New Mexico bar; proof of attendance at an AI CLE; Amazon Defendants permitted to move for fees and costs; costs may not be charged to the clients | Sep 2026 |
| Smith v. Verra Mobility Corporation | M.D. Fla. U.S. District Court, Middle District of Florida, Tampa Division | May 2026 | ChatGPT among other AI tools (the court recounts that counsel "acknowledges that he used artificial intelligence tools, including ChatGPT, to research and draft" the motion) | Court sanction | Non-monetary: counsel ordered to give his client, the School Board of Polk County, copies of the show-cause order, his response, and the sanctions order by May 5, 2026, and to notify the court of compliance by May 6, 2026 | Sep 2026 |
| Braun v. Day | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Apr 2026 | Unidentified (the court stated it "is concerned that Ms. Braun utilized AI in her drafting" and ordered her to identify any AI-generated portions; no tool is named in the docket entries read) | Other | None | Sep 2026 |
| Superb Motors Inc. v. Deo | E.D.N.Y. U.S. District Court, Eastern District of New York | Apr 2026 | Unidentified (the court describes the two citations as AI-generated; Thomasson declared that he does not use AI, blamed viruses and malware on his computer, and identified Google as one of his research tools) | Court sanction | $1,500 payable into the Registry of the Court by May 15, 2026; grievance referral declined | Sep 2026 |
| Adams v. Kiewit Infrastructure West Company | D. Ariz. U.S. District Court, District of Arizona | Apr 2026 | Generative AI, by inference (the court: "These hallucinations allow the Court to infer that Plaintiff prepared her filing with the use of generative artificial intelligence"; no tool named) | Warning | None | Sep 2026 |
| Doe v. Baltimore City Board of School Commissioners | D. Md. U.S. District Court, District of Maryland | Apr 2026 | Unidentified (the court calls one citation fabricated and its show-cause letter order refers to erroneous or nonexistent citations and quotations, but neither order mentions AI or names a tool) | Other | None | Sep 2026 |
| Jimenez-Fogarty v. Fogarty | S.D.N.Y. U.S. District Court, Southern District of New York | Apr 2026 | Unidentified AI program (the court found that counsel "used an AI program that generated the fabricated citations" and declined to credit her suggestion that LexisNexis's AI features supplied them) | Court sanction | $2,500 payable to the Clerk; copy of the order to the client; letter filing the order with the judge in each pending case where she is counsel of record; sworn statement of compliance | Sep 2026 |
| Jones v. Reed's, Inc. | N.D. Cal. U.S. District Court, Northern District of California | Apr 2026 | Unidentified (the court says the misstatement may be "the result of hallucination by artificial intelligence or lack of diligence" and does not find which; no tool named) | Warning | None | Sep 2026 |
| Spiehs v. Smith | D. Kan. U.S. District Court, District of Kansas | Apr 2026 | Suspected, not found: the court "strongly suspects this is a product of the use of artificial intelligence" because a Westlaw search for the quotes returned no exact results; no tool identified | Warning | None | Sep 2026 |
| Trejo v. Amaya Hernandez | Md. App. Ct. Appellate Court of Maryland | Apr 2026 | Unidentified (the opinion finds that three of the seven cases cited in the appellant's brief do not exist but does not mention AI or name a tool) | Court sanction | Non-monetary: portions of the appellant's brief relying on the non-existent cases struck | Sep 2026 |
| Chaney v. Transdev Services Inc. | C.D. Cal. U.S. District Court, Central District of California | Apr 2026 | LexisNexis+ and its drafting feature Protégé (counsel admitted using them to draft portions of the brief) | Court sanction | $2,500 payable to the Court ($500 for one use of the fabricated case and $1,000 for each of two more); declaration of the AI use and the bad-faith findings to be filed in every C.D. Cal. case where counsel appears and emailed to every other C.D. Cal. judge's chambers | Sep 2026 |
| Greenberg v. First Bank, Inc. | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, South District (Governor George Deukmejian Courthouse) | Apr 2026 | Unidentified (the court recited the bank's allegation that plaintiffs cited "a non-existent, AI-generated case" and found only that the case "does not appear to exist"; it made no finding that AI was used, and no tool is named) | Warning | None | Sep 2026 |
| Tunstall v. Alabama Department of Corrections | N.D. Ala. U.S. District Court, Northern District of Alabama, Southern Division | Apr 2026 | Unidentified (the opinion finds a quotation absent from the cited case and calls it a fabricated quotation, but does not mention AI or name a tool) | Warning | None | Sep 2026 |
| Ibach v. Stewart | Ala. Sup. Ct. Supreme Court of Alabama | Apr 2026 | Unnamed "AI research tool" (counsel's own description in the reply brief); at a hearing, counsel admitted he improperly used AI to obtain the authorities | Court sanction | $17,200 in attorney fees and costs to the appellee; double costs of appeal payable to the Court; no further filings in the Supreme Court of Alabama without the co-signature of another attorney in good standing; referral to the Alabama State Bar; appeal dismissed as a sanction | Sep 2026 |
| Dennison v. Caudill | S.D. Ind. U.S. District Court, Southern District of Indiana, Terre Haute Division | Apr 2026 | Unidentified (the order reports a case citation the court could not find and mischaracterized statutes, and directs the plaintiff to the court's AI-disclosure notice, but does not find that AI was used) | Warning | None | Sep 2026 |
| In re Paula M. Miller | Tex. App. (1st Dist.) Court of Appeals of Texas, First District (Houston) | Apr 2026 | Unidentified (only a concurrence says the petition's attributions and quotations "strongly appear to be AI-fabricated hallucinations"; the per curiam opinion is silent; no tool named) | Other | None | Sep 2026 |
| Krista C. Geddes v. LoanCare, LLC, et al. | E.D. Cal. U.S. District Court, Eastern District of California | Apr 2026 | Unidentified (the order voices concern about generative AI but says its use "is not conclusive here" and does not attribute the misquotes to AI or name a tool) | Court sanction | $1,000, payable within 30 days; Plaintiff ordered to serve a copy of the order on the California Bar Association and to file a notice of compliance within 60 days | Sep 2026 |
| Primerica Life Insurance Co. v. Finlayson | D. Utah U.S. District Court, District of Utah | Apr 2026 | Unspecified generative AI | Warning | None | Sep 2026 |
| Williams v. Honl | Or. Ct. App. Court of Appeals of Oregon | Apr 2026 | Unspecified generative AI | Court sanction | $8,044.25 | May 2026 |
| Zhang v. Zhang | Nev. Sup. Ct. Supreme Court of Nevada | Apr 2026 | Unidentified (neither order mentions artificial intelligence; the court stated its research "indicates" that two cited cases "are fictional" and that two real cases do not support the propositions cited) | Court sanction | $250 to the Supreme Court Law Library for violating NRAP 28(h) and NRAP 32(a)(9); referral of attorney Michael Lin to the State Bar of Nevada for investigation under SCR 104 and 105; request to file a corrected opening brief denied | Sep 2026 |
| Bunce v. Visual Technology Innovations, Inc. | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Apr 2026 | ChatGPT (2025 order); AI-assisted legal research tool (2026 order, specific product not named) | Court sanction | $7,500 (two sanctions: $2,500 in Feb 2025 and $5,000 in Apr 2026) | Apr 2026 |
| In re Prince Global Holdings Limited, et al. | Bankr. S.D.N.Y. U.S. Bankruptcy Court, Southern District of New York | Apr 2026 | Unspecified generative AI | Other | None | Sep 2026 |
| Harris v. Elementis Specialties, Inc. | C.D. Cal. U.S. District Court, Central District of California | Apr 2026 | Unidentified AI (the order states that plaintiff cites, "and Defendant has confirmed," that "its use of AI resulted in several citation errors"; no tool is named) | Warning | None; plaintiff's motion for sanctions was denied (no bad faith found; removal not objectively unreasonable), and defendant and its counsel were "explicitly warned" that the court will consider the incident if similar AI-related "mistakes" recur | Sep 2026 |
| Essandoh v. Capital One Bank NA | E.D. Tex. U.S. District Court, Eastern District of Texas, Sherman Division | Apr 2026 | Generative AI (the pro se plaintiff admitted at an April 16, 2026 hearing that inaccuracies in his part of a joint report resulted from reliance on generative AI; tool not identified) | Warning | None | Sep 2026 |
| Saunders v. Albertsons/Safeway, LLC | D. Colo. U.S. District Court, District of Colorado | Apr 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Redmond v. Dairy Farmers of America | D. Kan. U.S. District Court, District of Kansas | Apr 2026 | Not determined (the court "strongly suspects" the errors "are attributable to the careless use of generative artificial intelligence"; no tool is named and no finding of AI use is made) | Warning | None | Sep 2026 |
| White v. Walmart, Inc. | S.D. Ind. U.S. District Court, Southern District of Indiana, Indianapolis Division | Apr 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Hydroxie LLC v. Flame USA Inc | C.D. Cal. U.S. District Court, Central District of California | Apr 2026 | Not determined (the court wrote "[t]o the extent that Plaintiff has relied on artificial intelligence"; it made no finding that AI was used and named no tool) | Warning | None; plaintiff was admonished that future citations to authority that do not appear to exist will result in an order to show cause re sanctions | Sep 2026 |
| Rodriguez v. Rodriguez | Fla. 6th DCA Florida Sixth District Court of Appeal | Apr 2026 | Unspecified generative AI | Pending | Pending | Sep 2026 |
| Gamez v. County of Fresno | E.D. Cal. U.S. District Court, Eastern District of California | Apr 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| In re Troylond Malon Wise | Bankr. W.D. La. U.S. Bankruptcy Court, Western District of Louisiana, Lafayette Division | Apr 2026 | Unspecified generative AI | Court sanction | $2,750 | Apr 2026 |
| Moore v. MC Architects Inc. | D. Haw. U.S. District Court, District of Hawaii | Apr 2026 | Unnamed AI tools used by the client (per the sanctions order, counsel explained that the plaintiff used AI tools in preparing the oppositions; no tool is identified) | Court sanction | $1,000 against Attorney Frederick Arensmeyer personally, payable to the Clerk within seven days | Sep 2026 |
| Obi v. Cook County, Illinois | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Apr 2026 | Generative AI, tool not identified (the court states that "Plaintiff generated each brief using AI" and that her motion "is riddled with AI hallucinations") | Court sanction | $5,000 under Rule 11, payable to the Clerk of the Court within two weeks; Rule 59(e) motion stricken under Local Rule 7.1 | Sep 2026 |
| Hocog v. Cook-Huynh | Guam Super. Ct. Superior Court of Guam | Apr 2026 | Unspecified generative AI | Court sanction | $1,500 | Oct 2026 |
| Thanh Nguy v. Jabil Inc. | N.D. Cal. U.S. District Court, Northern District of California | Apr 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| In re Kathleen A. Rabon | Bankr. D. Conn. U.S. Bankruptcy Court, District of Connecticut | Apr 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Modern Floor Specialists, Inc. v. City of Los Angeles | C.D. Cal. U.S. District Court, Central District of California | Apr 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| United States v. Farris | 6th Cir. U.S. Court of Appeals for the Sixth Circuit | Apr 2026 | Westlaw CoCounsel | Court sanction | Not stated | Oct 2026 |
| In re Philips Recalled CPAP, Bi-Level PAP, and Mechanical Ventilator Products Liability Litigation (Gravelyn Transfer Order) | J.P.M.L. United States Judicial Panel on Multidistrict Litigation (transferee: W.D. Pa.) | Apr 2026 | Unidentified generative AI (the Panel said the misrepresentations suggest counsel "may have used generative artificial intelligence," though "it is possible counsel used some other unreliable source"; no tool is named) | Warning | None (admonishment and warning) | Sep 2026 |
| Stanford v. Leinart | Tex. App. Court of Appeals of Texas, Second District (Fort Worth) | Apr 2026 | Unidentified (the court found a 'hallucinated' authority 'generated from the use of artificial intelligence'; no specific tool named) | Warning | None | Oct 2026 |
| Patrick Hrdlichka v. Samantha Bengston | Ark. Ct. App. Court of Appeals of Arkansas | Apr 2026 | Unidentified (the court found the brief cited 'fictitious' cases not in any legal database; no AI tool named in the opinion) | Court sanction | Not stated | Sep 2026 |
| Maldonado v. Professional Animal Retirement Center | N.D. Ind. U.S. District Court, Northern District of Indiana, Fort Wayne Division | Apr 2026 | Not identified (the court suspected generative AI; counsel did not directly address it, and a paralegal's declaration mentions "AI-assisted research features") | Court sanction | $1,500 | Sep 2026 |
| Allen v. Western Governors University | D. Nev. U.S. District Court, District of Nevada | Mar 2026 | Generative AI (court found plaintiff either fabricated citations or "enlisted assistance of AI, which misrepresented and fabricated cases" without verification) | Court sanction | Defendants' attorneys' fees and costs incurred from the false citations (amount unquantified in order); case dismissed with prejudice | May 2026 |
| Christopher A. Ambrose v. Bandy X. Lee | D. Conn. U.S. District Court, District of Connecticut | Mar 2026 | Unspecified generative AI | Warning | None (warning only; the Court declared a no-tolerance policy for AI-assisted briefing that hallucinates legal propositions or severely misstates the law, and stated such filings 'will often result in sanctions absent reasonable excuse') | May 2026 |
| Colbert v. County of Riverside | C.D. Cal. U.S. District Court, Central District of California | Mar 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Feldman v. District 6 Board of Education | C.D. Ill. U.S. District Court, Central District of Illinois | Mar 2026 | Not mentioned in the order | Warning | None | May 2026 |
| Ford v. Sherwin-Williams | D. Kan. U.S. District Court for the District of Kansas | Mar 2026 | Unidentified generative AI (the court inferred AI use from a fabricated citation; Mr. Ford did not identify a specific tool on the record) | Warning | None | May 2026 |
| FTC v. Noland | D. Ariz. U.S. District Court, District of Arizona | Mar 2026 | Generative AI suspected, specific tool not named in the order | Warning | None | Oct 2026 |
| Heimkes v. Fairhope Motorcoach Resort Condominium Owners Ass'n, Inc. | S.D. Ala. U.S. District Court, Southern District of Alabama | Mar 2026 | Cocounsel | Court sanction | $55,597 | Apr 2026 |
| Mohamed Hussain et al. v. Mansoor Quraishi et al. | Conn. Super. Ct. Superior Court of Connecticut, Judicial District of Tolland at Rockville | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Montes v. Suns Legacy Partners LLC | D. Ariz. U.S. District Court, District of Arizona | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Quandel Construction Group, Inc. v. Hunt Construction Group, Inc. | S.D. Ohio U.S. District Court, Southern District of Ohio | Mar 2026 | Disputed (defendants' counsel denied using generative AI; plaintiff's counsel hypothesized a GenAI hallucination; the court declined to make a formal AI-use finding) | Other | None | Oct 2026 |
| Rivera v. Triad Properties Corporation | N.D. Ala. U.S. District Court, Northern District of Alabama | Mar 2026 | ChatGPT | Court sanction | $47,056.90 | Apr 2026 |
| Zavadovsky v. Republic of Austria | D.D.C. U.S. District Court, District of Columbia | Mar 2026 | Generative AI implied; the order references citations characteristic of AI hallucination output | Warning | None | Oct 2026 |
| Dec v. Mullin | 7th Cir. U.S. Court of Appeals for the Seventh Circuit | Mar 2026 | AI-generated (court found error not knowing/intentional) | Court sanction | None (public admonishment, no monetary sanction) | Sep 2026 |
| Fleck v. Del-One Federal Credit Union | D. Or. U.S. District Court, District of Oregon | Mar 2026 | Generative AI tools (plaintiff's company "MarketPulse AI" systems, specific product not identified) | Warning | None | Oct 2026 |
| Beedemariam Kassaw v. Wal-Mart Corporation | W.D.N.Y. U.S. District Court, Western District of New York | Mar 2026 | Implied (court found apparent use of generative AI; specific tool not identified on the record) | Court sanction | Not stated | May 2026 |
| Morgan v. V2X, Inc. | D. Colo. U.S. District Court, District of Colorado | Mar 2026 | Consumer AI platforms (specific tools to be disclosed by plaintiff) | Other | None | May 2026 |
| 76 Route 6 Holdings Inc. v. Town of Yorktown | S.D.N.Y. U.S. District Court, Southern District of New York | Mar 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Souza v. City of Fitchburg | D. Mass. U.S. District Court, District of Massachusetts | Mar 2026 | Generative AI (court found the pro se plaintiff relied on generative AI to draft his filings; specific tool not identified) | Warning | None | Oct 2026 |
| Williams v. Chicago Board of Education | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Mar 2026 | Unspecified generative AI | Other | None | May 2026 |
| Williams v. Crystal Springs Apartments LLC | D. Ariz. U.S. District Court, District of Arizona | Mar 2026 | Generative AI tools listed by the court included ChatGPT, Claude, Copilot, DeepSeek, Google Gemini, and Grok | Other | None | May 2026 |
| Amtrust North America o/b/o Justin McGinness v. Liberty Mutual Insurance Company | N.J. Super. Ct. App. Div. Superior Court of New Jersey, Appellate Division | Mar 2026 | Unspecified generative AI | Court sanction | $1,000 | Apr 2026 |
| McCarthy v. United States Drug Enforcement Administration | 3d Cir. U.S. Court of Appeals for the Third Circuit | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Andrea K. Tantaros v. Fox News Network, LLC | S.D.N.Y. U.S. District Court, Southern District of New York | Mar 2026 | Implied (court suspected AI hallucinations; specific tool not identified on the record) | Court sanction | Not stated | May 2026 |
| The Advocates for Human Rights v. U.S. Department of Homeland Security | D. Minn. U.S. District Court, District of Minnesota | Mar 2026 | Unidentified (the order finds that quotations attributed to an Eighth Circuit case do not appear in it but does not mention AI or name a tool) | Other | None | Sep 2026 |
| Baker v. Rastelli Foods LLC | D.N.J. U.S. District Court, District of New Jersey | Mar 2026 | Unspecified generative AI | Warning | None monetary (warning + filing precondition: any future amended pleading or similar action in this Court must include PDF copies of each cited case with the supporting text highlighted; non-compliance is grounds for show-cause and sanctions) | May 2026 |
| Mission Critical Project Services, Inc. | GAO U.S. Government Accountability Office | Mar 2026 | Unidentified (GAO said the erroneous citations "bear the hallmarks of the use of a large-language model or other artificial intelligence (AI) without adequate verification"; no tool named) | Warning | None | Apr 2026 |
| State National Insurance Company, Inc. v. Treadwell | N.D. Ala. U.S. District Court, Northern District of Alabama | Mar 2026 | ChatGPT and OpenCase | Court sanction | Not stated | Apr 2026 |
| Wallace v. PennyMac Loan Services, LLC | D. Nev. U.S. District Court, District of Nevada | Mar 2026 | Generative AI (court named ChatGPT as exemplar; specific tool not affirmatively identified) | Warning | None | Oct 2026 |
| Gouveia v. Meridian Financial Investments, LLC | Fla. 4th DCA District Court of Appeal of the State of Florida, Fourth District | Mar 2026 | Large language model (the court says it "appears" the appellant used one; no tool identified). The limerick in the opinion is attributed to ChatGPT 5.2 | Warning | None | Sep 2026 |
| Biglow v. Dell Technologies, Inc. | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Mar 2026 | ChatGPT (named in opinion as an example of generative AI) | Warning | None | Sep 2026 |
| Harris v. Washington County (Purgatory Correctional Facility) | D. Utah U.S. District Court, District of Utah | Mar 2026 | Generative AI generally; specific tool not named in the order | Other | None | May 2026 |
| Layton v. Layton | Ariz. Ct. App. Arizona Court of Appeals, Division One | Mar 2026 | Generative AI suspected, specific tool not named in the opinion | Warning | None | Oct 2026 |
| Segui v. Moniz | D. Ariz. U.S. District Court, District of Arizona | Mar 2026 | Unspecified generative AI | Pending | Pending | Oct 2026 |
| Jane Doe, et al. v. Lincoln Consolidated Schools, et al. | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Moulder v. Davis School District | D. Utah U.S. District Court, District of Utah | Mar 2026 | Unspecified generative AI | Court sanction | $1,525.50 | Apr 2026 |
| Stafford v. Taffet | D. Or. U.S. District Court, District of Oregon (Medford Division) | Mar 2026 | Generative AI (specific product not identified by court; "hallucinated" citations consistent with AI-generated content) | Other | None | May 2026 |
| Pamela Blair v. Sanctuary Bluff Homeowners Association, Inc. | Ky. Ct. App. Kentucky Court of Appeals | Mar 2026 | Unidentified generative AI (Blair admitted using AI; no specific tool named) | Court sanction | Not stated | Sep 2026 |
| Daniel Gentry v. Calvin Thompson, et al. | E.D. La. U.S. District Court, Eastern District of Louisiana | Mar 2026 | ChatGPT | Court sanction | $1,250 | May 2026 |
| Lopez v. Mead Johnson Nutrition Company | N.D. Cal. U.S. District Court, Northern District of California | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Prososki v. Regan | Neb. Sup. Ct. Nebraska Supreme Court | Mar 2026 | AI (unspecified; appellant's counsel denied AI use, but appellee asserted the brief's nonexistent and inaccurate citations were the product of generative AI) | Court sanction | Not stated | Sep 2026 |
| State v. Coleman | Ohio Ct. App. (11th Dist.) Ohio Court of Appeals, Eleventh Appellate District (Ashtabula County) | Mar 2026 | ChatGPT | Court sanction | $2,000 | May 2026 |
| Brownfield v. Cherokee County School District No. 35 | E.D. Okla. U.S. District Court, Eastern District of Oklahoma | Mar 2026 | Generative AI (specific tool not identified on the record) | Court sanction | $500 | May 2026 |
| Espinoza v. M&R Construction Group Inc. | Sup. Ct. Kings Cty. New York Supreme Court, Kings County | Mar 2026 | Unidentified (the decision calls the citation "apparently fabricated caselaw" but does not mention AI or name a tool) | Pending | None yet; the decision scheduled a sanctions hearing for April 10, 2026 | Sep 2026 |
| Pittman v. Hazel and Olive, Inc. | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Mar 2026 | Unidentified (the order states that counsel "admitted that he relied on artificial intelligence" and "submitted fake cases"; no tool is named) | Court sanction | Counsel to pay all costs and fees defendant incurred in defending the lawsuit (amount left to the parties to determine); case to be dismissed with prejudice once payment is finalized | Sep 2026 |
| Prisbrey v. Prisbrey | Utah Ct. App. Utah Court of Appeals | Mar 2026 | Unspecified generative AI | Other | None | May 2026 |
| Sheerer v. Panas | Cal. Ct. App. Court of Appeal of California, First Appellate District, Division Four | Mar 2026 | Generative AI (Panas admitted in a post-argument declaration that his error was 'caused by his use of an AI tool and his failure to verify his citations'; specific tool not named) | Court sanction | Not stated | May 2026 |
| Doiban v. Oregon Liquor and Cannabis Commission | Or. Ct. App. Oregon Court of Appeals | Mar 2026 | Google and Safari AI-generated search summaries (not a dedicated legal AI tool) | Court sanction | $10,000 | May 2026 |
| Forest Ridge Townhomes Corporation of Greensboro v. Heag Pain Management Center, P.A. | N.C. Ct. App. North Carolina Court of Appeals | Mar 2026 | Perplexity.AI, Professional Version (per respondents' counsel's statement in a trial-court motion, as quoted in the opinion; the court said only that some authority "appears to be AI-generated") | Warning | None; Rule 34 sanctions declined | Sep 2026 |
| Francois v. Vive Financial | Fla. 4th DCA Florida Fourth District Court of Appeal | Mar 2026 | Generative AI (court identified 'reliance on generative artificial-intelligence tools' as a cause of fictitious citations; specific tool not named) | Warning | None | Sep 2026 |
| Kennon v. Ashley | D. Kan. U.S. District Court, District of Kansas | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | Oct 2026 |
| Riddle Aggregates, LLC, Ornstein-Schuler, LLC, Tax Matters Partner v. Commissioner | U.S. Tax Ct. United States Tax Court | Mar 2026 | Not determined (the witness testified he used Grammarly on the reports; he uses ChatGPT and Gemini in his practice but did not recall using them for these reports) | Other | None | Sep 2026 |
| Jesse Hsien Chueh Yao v. University of South Florida Board of Trustees | M.D. Fla. U.S. District Court, Middle District of Florida, Tampa Division | Mar 2026 | Suspected, not found (a defendant "suspects that Plaintiff used artificial intelligence" to draft his oppositions, and the court noted that he "does not deny" it; neither order finds that AI was used or names a tool) | Warning | None | Sep 2026 |
| Singletary v. SWBC Mortgage Corp. | 5th Cir. U.S. Court of Appeals for the Fifth Circuit | Mar 2026 | Unspecified; the opinion refers to 'AI-hallucinated case law' without naming a particular tool. | Warning | None | Sep 2026 |
| Wilkes v. Canyons School District | D. Utah U.S. District Court, District of Utah, Central Division | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Anderson v. AKAM Associates, Inc. | Sup. Ct. N.Y. Cty. New York Supreme Court, New York County | Mar 2026 | Unidentified (neither written order mentions AI; at the fee hearing defense counsel called the case "AI-hallucinated" and said the plaintiff did not acknowledge that it was created by "ChatGPT or the like," and the court spoke of AI in general terms) | Court sanction | $17,482.89 judgment for the defendants' attorneys' fees on the enforcement motion (at the hearing, before the amount was fixed, the court said paying the fees was "sanction enough"); no separate penalty and no grievance referral | Sep 2026 |
| Ioio v. City of New York | 2d Cir. U.S. Court of Appeals for the Second Circuit | Mar 2026 | Unidentified (the summary order says two citations in the opening brief "do not appear to exist" but does not mention AI or any tool) | Other | None imposed; attorneys Jo Saint-George and Tricia S. Lindsay referred to the Second Circuit's Grievance Panel under Local Rule 46.2 | Sep 2026 |
| Appeals of DSME Construction Co., Ltd. | ASBCA Armed Services Board of Contract Appeals (ASBCA) | Mar 2026 | Implied (generative AI; appellant did not confirm or deny use) | Court sanction | Not stated | Oct 2026 |
| In the Matter of a Member of the State Bar of Arizona, John A. Griffiths | Ariz. PDJ Presiding Disciplinary Judge, Supreme Court of Arizona | Mar 2026 | Eve.legal (the PDJ's order states that Griffiths "used Eve.legal (an AI legal research service) to prepare a draft response"; the conditional admissions say the same) | Bar discipline | Reprimand; State Bar costs and expenses of $1,200.00 | Sep 2026 |
| Taylor v. Las Vegas Metropolitan Police Department | D. Nev. U.S. District Court, District of Nevada | Mar 2026 | Generative AI (court characterized citations as "hallucinogenic"; specific tool not identified) | Warning | None | Oct 2026 |
| Whiting v. City of Athens, Tenn. | 6th Cir. U.S. Court of Appeals for the Sixth Circuit | Mar 2026 | Unspecified generative AI | Court sanction | $30,000 | Sep 2026 |
| Donaghy v. Zoning Board of Review of the Town of North Kingstown | R.I. Super. Ct. Rhode Island Superior Court, Washington County | Mar 2026 | Unidentified (the court listed "the rise of artificial intelligence" as one possible explanation alongside "a short deadline" or "a simple error"; it made no finding on AI use and named no tool) | Warning | None | Sep 2026 |
| Hartmann v. Davidson | N.D. Tex. U.S. District Court, Northern District of Texas, Dallas Division | Mar 2026 | Generative AI (tool not specified by court; pro se plaintiff disclosed use) | Other | None | May 2026 |
| In re Scott Mitchell Obeginski | Tex. App. (9th Dist.) Texas Court of Appeals, Ninth District | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | Sep 2026 |
| Suiter v. GM - General Motors, LLC | W.D. Va. U.S. District Court, Western District of Virginia | Mar 2026 | Unspecified generative AI (court found filings displayed characteristics 'observed in filings made with generative artificial intelligence programs') | Warning | None | Oct 2026 |
| Dillon v. Stephenson | W.D. Okla. U.S. District Court, Western District of Oklahoma | Mar 2026 | Implied (AI research assistant; specific tool not identified) | Court sanction | Not stated | Apr 2026 |
| In re Eric Chibueze Nwaubani | 4th Cir. U.S. Court of Appeals for the Fourth Circuit | Mar 2026 | Technology-agnostic. The court named ChatGPT, Google Gemini, Microsoft Copilot, and Claude as examples but declined to determine which tool, if any, was used. | Bar discipline | Not stated | Sep 2026 |
| Donte McClellon v. E. Rickard, Warden of FCI Otisville | S.D.N.Y. U.S. District Court, Southern District of New York | Mar 2026 | Implied (Magistrate Judge identified hallmarks of AI-generated fabricated cases; specific tool not identified) | Court sanction | Not stated | May 2026 |
| Nai v. National Asset Mortgage, LLC | W.D. Mich. U.S. District Court, Western District of Michigan, Southern Division | Mar 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Samantha Roussell v. The Bank of New York Mellon | Fla. 4th DCA Florida Fourth District Court of Appeal | Mar 2026 | Generative AI (court characterized nonexistent citations as 'hallucinated cases'; explicitly addressed AI use in briefing) | Warning | None | Sep 2026 |
| Traver v. General Motors Financial Company, Inc. | D. Mass. U.S. District Court, District of Massachusetts | Mar 2026 | Generative AI implied; the order references fabricated case-law citations characteristic of AI hallucination output | Warning | None | Sep 2026 |
| Allen v. Casper | N.D. Ill. U.S. District Court, Northern District of Illinois | Mar 2026 | Unspecified generative AI | Court sanction | $1,500 | May 2026 |
| Brown v. State of Mississippi | Miss. Ct. App. Court of Appeals of Mississippi | Mar 2026 | Unspecified generative AI | Other | None | Sep 2026 |
| Hunter v. TForce Freight Inc. | D. Ariz. U.S. District Court, District of Arizona | Mar 2026 | Generative AI (specific tool not named in the order) | Other | None | May 2026 |
| Platt v. Volunteers of America Ohio & Indiana | S.D. Ind. U.S. District Court, Southern District of Indiana | Mar 2026 | Not identified on the order; the court suspected AI use from the pattern of nonexistent and misrepresented citations | Court sanction | Not stated | May 2026 |
| United States v. Simmons | E.D.N.C. U.S. District Court, Eastern District of North Carolina, Eastern Division | Mar 2026 | Unnamed AI tool (defense counsel told the court at the October 9, 2025 hearing that she "typed some things in on A.I." and filed a first draft by mistake; the court found the memorandum "bore the hallmarks of generation, at least in some parts, by Artificial Intelligence"; no tool is named) | Other | None | Sep 2026 |
| M7 Indústria e Comércio de Compensados e Laminados Ltda. v. U.S. Structural Plywood Integrity Coalition | S.D.N.Y. U.S. District Court, Southern District of New York | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Slay v. Ross | Ga. Ct. App. Court of Appeals of Georgia | Mar 2026 | Implied (specific generative AI product not identified on the face of the opinion) | Warning | None | Oct 2026 |
| Clark v. CoreCivic, Inc. | W.D. Okla. U.S. District Court, Western District of Oklahoma | Mar 2026 | Generative AI (specific tool not identified on the record) | Warning | None (admonishment only; future violations may draw sanctions) | Oct 2026 |
| Van Etten v. Fattman | D. Mass. U.S. District Court, District of Massachusetts | Mar 2026 | Generative AI implied; the order addresses fabricated content characteristic of AI hallucination output | Warning | None | Oct 2026 |
| Harwell v. WestCare Nevada, Inc. | D. Nev. U.S. District Court, District of Nevada | Mar 2026 | ChatGPT (R&G classified ChatGPT; court referenced generative AI generally with ChatGPT as exemplar) | Warning | None | Oct 2026 |
| Hatch v. College Ave Student Loans | N.D. Ill. U.S. District Court, Northern District of Illinois, Eastern Division | Mar 2026 | Not mentioned in the order | Pending | Pending | Sep 2026 |
| Kattom v. Bondi | W.D. La. U.S. District Court, Western District of Louisiana, Alexandria Division | Mar 2026 | ChatGPT | Court sanction | $1,000 | May 2026 |
| In re Estate of Kuerschner (Kuerschner v. Kuerschner) | Ariz. Ct. App. Arizona Court of Appeals, Division One | Mar 2026 | Unidentified (the decision finds 25 citations "made up or contain substantial errors" and says she continues "to fabricate citations," but does not mention AI) | Court sanction | Appeal dismissed under ARCAP 25; personal representative awarded reasonable attorney fees and costs under ARCAP 25 upon compliance with ARCAP 21 (amount not stated) | Sep 2026 |
| In re the Domestic Partnership of Torres Campos & Munoz (Torres Campos v. Munoz) | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division One | Mar 2026 | Unspecified generative AI | Court sanction | $5,000 | May 2026 |
| Woodward Harbor LLC v. City of Mandeville | E.D. La. U.S. District Court for the Eastern District of Louisiana | Mar 2026 | Westlaw Precision AI and ChatGPT (per Walker's sworn declaration of February 12, 2026, ECF No. 104-1) | Court sanction | $1,000 personal sanction against attorney John R. Walker, payable to the Clerk of Court | Sep 2026 |
| Dixon v. MultiCare Health System | W.D. Wash. U.S. District Court, Western District of Washington | Mar 2026 | Unspecified generative AI | Warning | None (warning only; the Court reserved monetary sanctions for any future repetition, stating 'If, in the future, Dixon repeats this behavior, monetary sanctions may be awarded') | May 2026 |
| Ford v. Troy City School District | N.D.N.Y. U.S. District Court, Northern District of New York | Mar 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Medal v. Amazon.com Services LLC | W.D. Wash. U.S. District Court, Western District of Washington | Mar 2026 | Unspecified generative AI | Pending | Pending | Oct 2026 |
| Vernieri v. Dyno Nobel Americas | D. Utah U.S. District Court, District of Utah | Mar 2026 | Generative AI generally; specific tool not named in the order | Warning | None | Oct 2026 |
| Doe 1 v. Shirley Lai | C.D. Cal. U.S. District Court, Central District of California | Mar 2026 | Unidentified (the February 17, 2026 order said such errors "often indicate the presence of artificial intelligence-generated hallucinations"; neither order finds AI use or names a tool, and counsel's sworn response attributed the errors to drafting and said he researched on Westlaw) | Warning | None | Sep 2026 |
| Hardy v. Whitaker | E.D. Mich. U.S. District Court, Eastern District of Michigan | Mar 2026 | Suspected generative AI, tool not identified (the magistrate judge's R&R states "The Court suspects that the fake citations result from Hardy using generative artificial intelligence (AI)"; the adopting order does not mention AI) | Court sanction | Not stated | Sep 2026 |
| Put A Bird On It, LLC v. Seattle Arena Holdings, LLC | Wash. Ct. App. Washington Court of Appeals, Division One | Mar 2026 | AI-based search engines (unidentified) | Warning | None | Sep 2026 |
| Hicks v. City of Albany | Ga. Ct. App. Court of Appeals of Georgia | Feb 2026 | Unspecified generative AI | Other | None | Sep 2026 |
| Estate of Khallid Muhammad et al. v. Tupac Shakur Estate et al. | C.D. Cal. U.S. District Court, Central District of California | Feb 2026 | Suspected generative AI; the court ordered plaintiffs to disclose any AI use, and plaintiffs did not disclose any in response | Other | None | May 2026 |
| Perry v. Exeter Finance LLC | D. Ariz. U.S. District Court, District of Arizona | Feb 2026 | Generative AI suspected, specific tool not named in the order | Warning | None | Oct 2026 |
| Thomas v. The Quikrete Companies, LLC | W.D. Tex. U.S. District Court, Western District of Texas, San Antonio Division | Feb 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| United States v. Ponce | D. Nev. U.S. District Court, District of Nevada | Feb 2026 | Generative AI (court characterized citations as "hallucinogenic"; specific tool not identified) | Warning | None | Oct 2026 |
| In re Termination of Parental Rights as to H.K. | Ariz. Ct. App. Arizona Court of Appeals, Division One | Feb 2026 | Unidentified (the decision says Mother's answering brief contains "what appear to be hallucinated quotations" but does not mention AI or name a tool) | Other | None; the court will forward its decision to the State Bar of Arizona | Sep 2026 |
| Kettering Adventist Healthcare v. Sandra Collier | S.D. Ohio U.S. District Court, Southern District of Ohio | Feb 2026 | generative AI (admitted by counsel for preliminary case identification) | Court sanction | $7,500 | May 2026 |
| Lee v. Capital One Bank (USA), N.A. | D. Utah U.S. District Court, District of Utah | Feb 2026 | Generative AI generally; specific tool not named in the order | Warning | None | Oct 2026 |
| Mau v. City and County of Honolulu | D. Haw. U.S. District Court, District of Hawaii | Feb 2026 | None found (both sanctioned attorneys declared that they do not use AI for drafting legal documents, and the sanctions order states that they "did not use AI"; they said privilege and ethical obligations prevented them from explaining how the errors occurred) | Court sanction | $2,000 total ($1,000 against each of two attorneys, personally), payable to the United States District Court for the District of Hawaii within seven days | Sep 2026 |
| Villalovos-Gutierrez v. Van de Pol | E.D. Cal. U.S. District Court, Eastern District of California | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Evgeny Yaroshevsky v. Karlin | E.D.N.Y. U.S. District Court, Eastern District of New York | Feb 2026 | Google Gemini | Court sanction | Not stated | May 2026 |
| Zeus Realty Group LLC v. 1032 N Sycamore Owner LA, LLC | C.D. Cal. U.S. District Court, Central District of California | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Reynolds v. Progressive Technologies, Inc. | W.D. Tenn. U.S. District Court for the Western District of Tennessee | Feb 2026 | Unidentified generative AI (the court found that plaintiff cited 'fabricated legal authority' across multiple filings; specific tool not on the record) | Warning | None | Oct 2026 |
| Bixler v. Church of Scientology International | Cal. Ct. App. California Court of Appeal, Second Appellate District, Division Five | Feb 2026 | Unidentified (per the court's February 19, 2026 order, respondents' counsel conceded they prepared the brief "with the aid of artificial intelligence tools"; no tool is named) | Other | None imposed; the court gave notice under rule 8.276(c) that it was considering monetary sanctions, and its May 19, 2026 opinion does not address them | Sep 2026 |
| Pena v. Wells Fargo Bank | S.D. Fla. U.S. District Court, Southern District of Florida | Feb 2026 | Unidentified (the court found the plaintiffs likely obtained a citation from 'an unreliable source, such as artificial intelligence'; no specific tool named) | Warning | None | May 2026 |
| EFD USA, Inc. v. Band Pro Film and Digital, Inc. | Cal. Ct. App. California Court of Appeal, Second District, Division Three | Feb 2026 | Unidentified generative AI (trial counsel's 'AI consultant' used an unidentified 'AI system' to shorten the brief) | Court sanction | $900 | May 2026 |
| Fletcher v. Experian Information Solutions, Inc. | 5th Cir. U.S. Court of Appeals for the Fifth Circuit | Feb 2026 | Generative AI (unspecified) | Court sanction | $2,500 | Oct 2026 |
| Matter of Adapt Forward, LLC | GAO U.S. Government Accountability Office | Feb 2026 | Implied (AI/LLM-generated citations) | Other | None | May 2026 |
| Jones v. Target Corporation | D. Or. U.S. District Court, District of Oregon | Feb 2026 | Generative AI (specific product not identified by court; "hallucinated" case citations) | Court sanction | Not stated | May 2026 |
| Mardis v. Dealer Loyalty Protection | S.D. Ohio U.S. District Court, Southern District of Ohio | Feb 2026 | Unidentified generative AI (court found the citations to be 'AI-generated, hallucinated caselaw' without naming a specific product) | Warning | None | Oct 2026 |
| Martin v. ODS Community Dental Insurance | D. Or. U.S. District Court, District of Oregon | Feb 2026 | Generative AI (specific product not identified by court; "generative artificial intelligence" referenced in the order) | Warning | None | Oct 2026 |
| CHP 1010 McDowell, LLC v. Turpen (In re Escobedo) | Bankr. D. Colo. U.S. Bankruptcy Court, District of Colorado | Feb 2026 | Unspecified generative AI (the order describes 'prompts from some artificial intelligence guidance' visible in the motion text; specific tool not named) | Warning | None (warning only; the Court cautioned that further AI-citation failures may be sanctionable under Fed. R. Bankr. P. 9011) | May 2026 |
| In re Social Media Adolescent Addiction/Personal Injury Products Liability Litigation | N.D. Cal. U.S. District Court, Northern District of California | Feb 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| Creditors Adjustment Bureau, Inc. v. All Season Power LLC | C.D. Cal. U.S. District Court, Central District of California | Feb 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Matter of: G2 Ops, Inc. | GAO U.S. Government Accountability Office | Feb 2026 | Unidentified (GAO says the erroneous citations "bear the hallmarks of the use of a large-language model or other artificial intelligence (AI)"; no tool is named) | Warning | None | Sep 2026 |
| In re: Telexfree Securities Litigation | D. Mass. U.S. District Court, District of Massachusetts | Feb 2026 | Unspecified generative AI | Pending | Pending | Oct 2026 |
| Lindsey Newell v. The Law Offices of Travis R. Walker, P.A. | S.D. Fla. U.S. District Court, Southern District of Florida | Feb 2026 | Unspecified generative AI | Court sanction | $5,000 | May 2026 |
| Picon-Diaz v. Bondi | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Feb 2026 | Unspecified generative AI | Warning | None | Oct 2026 |
| Rosario v. Liberty Mutual Personal Insurance Company | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Feb 2026 | None found (the court wrote: "We have no reason to today find the abuse of artificial intelligence research. We instead see old-fashioned lack of diligence.") | Warning | None; sanctions deferred on condition that counsel email the memorandum to firm colleagues and file a certificate of compliance by February 17, 2026 | Sep 2026 |
| City of Dickinson v. Helgeson | N.D. Sup. Ct. Supreme Court of North Dakota | Feb 2026 | Implied (the court quoted Mezu v. Mezu that 'Fake or nonexistent legal citations typically are the result of AI “hallucinations.”' and said the source of the errors did not matter) | Court sanction | $500 | Sep 2026 |
| CVTEK, LLC | GAO U.S. Government Accountability Office | Feb 2026 | Westlaw CoCounsel | Warning | None | May 2026 |
| Legarza v. Northern Star (Alaska), Inc. | D. Alaska U.S. District Court, District of Alaska | Feb 2026 | Unspecified generative AI | Other | None | May 2026 |
| Rechlicz v. Price Point Builders, LLC | Ind. Ct. App. Court of Appeals of Indiana | Feb 2026 | Not identified; court characterized errant citation as a typographical mistake but framed the broader risk as generative AI hallucination | Warning | None | Oct 2026 |
| TQJ, LLC v. Esquivel | C.D. Cal. U.S. District Court, Central District of California | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Chumpitaz-Morales v. Bondi | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Feb 2026 | Generative AI inferred (panel: 'an artificial intelligence (AI) product (e.g., ChatGPT, Microsoft CoPilot)') | Other | None | May 2026 |
| Dodds v. Bridges | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Feb 2026 | Generative AI inferred (panel: 'such as ChatGPT'; Dodds attributed the citations to 'transcription errors' by an unnamed outside source who typed the brief) | Warning | None | Oct 2026 |
| Alberti v. District of Columbia | D.D.C. U.S. District Court for the District of Columbia | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Matter of Omid Zareh | N.Y. App. Div. 1st Dep't New York Supreme Court, Appellate Division, First Department | Feb 2026 | ChatGPT | Bar discipline | Not stated | May 2026 |
| Labonte v. BOKF, N.A. | D. Colo. U.S. District Court, District of Colorado | Feb 2026 | AI (implied; unspecified) | Other | None | May 2026 |
| William Parker v. Patrick "Pat" Labat, et al. | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Feb 2026 | Not determined (the show-cause order required counsel to state whether he used AI to prepare the brief; he did not respond) | Court sanction | Non-monetary Rule 11(b) sanction: a six-hour CLE course on employment law or legal research and writing within six months, with proof of attendance; and, for one year, a sworn statement with every document filed in the court verifying that counsel personally checked all citations and quotations | Sep 2026 |
| United States v. Clint Travis Rodgers | W.D. Mo. U.S. District Court, Western District of Missouri, Central Division | Feb 2026 | Unidentified (the court wrote that, "[i]f this is not an intentional misrepresentation to the Court, the Court suspects that Mr. Norrid may have used some form of artificial intelligence"; no tool is named and the order records no explanation from counsel) | Other | None | Sep 2026 |
| Amarsingh v. Frontier Airlines, Inc. | 10th Cir. U.S. Court of Appeals, Tenth Circuit | Feb 2026 | ChatGPT | Court sanction | $1,000 | Apr 2026 |
| Avenue Capital Group, LLC v. Strum | N.Y. Sup. Ct. Supreme Court of the State of New York, New York County | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Bruce v. United States | D.S.C. U.S. District Court, District of South Carolina | Feb 2026 | Generative AI implied; the order references generative AI programs that "hallucinate" cases | Warning | None | Oct 2026 |
| Peter L. Clinco, Deceased, C. M. Barone-Clinco, Successor in Interest, and C. M. Barone-Clinco v. Commissioner of Internal Revenue | U.S. Tax Court United States Tax Court | Feb 2026 | Unidentified (the court said three citations "appear to be hallucinations generated by a large language model AI" but that it is "not absolutely clear from the record" whether counsel used generative AI; no tool is named) | Warning | None | Sep 2026 |
| Cummins v. Becerra | E.D. Cal. U.S. District Court, Eastern District of California | Feb 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| Valve Corporation v. Rothschild | W.D. Wash. U.S. District Court, Western District of Washington, at Seattle | Feb 2026 | Unspecified generative AI | Pending | Pending | Oct 2026 |
| Raul Gonzales Davila v. Roblen, LLC f/d/b/a Vicolo Pizza Restaurant | D. Conn. U.S. District Court, District of Connecticut | Feb 2026 | Unspecified generative AI research tool | Court sanction | Not stated | Apr 2026 |
| Arkansas Department of Human Services v. April Ward and Minor Child | Ark. Supreme Court of Arkansas | Feb 2026 | Microsoft Office Copilot | Court sanction | Not stated | Sep 2026 |
| Flycatcher Corp. Ltd. v. Affable Avenue LLC | S.D.N.Y. U.S. District Court, Southern District of New York | Feb 2026 | NotebookLM, vLex, Paxton AI | Court sanction | Not stated | Apr 2026 |
| Button v. McCawley | S.D. Fla. U.S. District Court, Southern District of Florida | Feb 2026 | Unidentified (the court referred to "what appears to be Plaintiffs' frequent use of artificial intelligence"; the Buttons stated that they "do not rely on artificial intelligence to generate or fabricate legal authority"; no tool is named) | Court sanction | Not stated | Sep 2026 |
| Holmes v. University of Texas at Austin | W.D. Tex. U.S. District Court, Western District of Texas, Austin Division | Feb 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| In re the Matter of Abiud Rosas Carreon v. Maria G. Rosas Rivera | Ariz. Ct. App. Court of Appeals of Arizona, Division 1 | Feb 2026 | Unidentified (the decision quotes Mother's assertion that incomplete citations are "a sign of the use of [Artificial Intelligence]" but makes no AI finding of its own and names no tool) | Warning | None | Sep 2026 |
| Sophia Madigan v. Graco Inc. | D. Minn. U.S. District Court, District of Minnesota | Feb 2026 | Unspecified AI-based legal-research service | Other | None | May 2026 |
| Odunze v. Lake Effect | D. Utah U.S. District Court, District of Utah | Feb 2026 | Generative AI generally; specific tool not named in the order | Warning | None | Oct 2026 |
| Offen Petroleum LLC v. L&J Express LLC | D. Ariz. U.S. District Court, District of Arizona | Feb 2026 | Unidentified (the order flags a nonexistent case and inaccurate quotations but does not attribute them to AI or name a tool) | Warning | None (a one-sentence warning in footnote 1) | Sep 2026 |
| 1S REO Opportunity 1, LLC v. 223 Howard LLC | E.D.N.Y. U.S. District Court, Eastern District of New York | Feb 2026 | Unidentified (the order flags a fabricated citation but does not attribute it to AI or name a tool) | Other | None | May 2026 |
| Kabir v. WebMD LLC | D.N.J. U.S. District Court, District of New Jersey | Feb 2026 | Generative AI inferred from hallucinated case citations and from plaintiff's own Notice Regarding Use of Cognitive Artificial Intelligence (ECF No. 58); specific tool not identified | Court sanction | Not stated | Oct 2026 |
| Kizzie Sims v. Board of County Commissioners for Oklahoma County | W.D. Okla. U.S. District Court, Western District of Oklahoma | Feb 2026 | Unnamed AI drafting tool (per the order, plaintiff's counsel acknowledged using an AI drafting tool to assist in preparing his brief) | Other | None | Sep 2026 |
| Lexos Media IP, LLC v. Overstock.com, Inc. | D. Kan. U.S. District Court for the District of Kansas | Feb 2026 | ChatGPT | Court sanction | $12,000 total across four attorneys ($5,000 + $3,000 + $3,000 + $1,000); fifth attorney released from monetary sanctions | Apr 2026 |
| Mills v. City of St. Louis | E.D. Mo. U.S. District Court, Eastern District of Missouri, Eastern Division | Jan 2026 | Generative AI (the court found plaintiff's filings 'bear the hallmarks of artificial intelligence hallucinations'; plaintiff acknowledged using 'electronic drafting tools that paraphrase legal principles' but did not identify a specific tool) | Court sanction | Not stated | May 2026 |
| Schaaf v. Nellis Auction Holdings, LLC | D. Nev. U.S. District Court, District of Nevada | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| SEC v. Nantomah | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Jan 2026 | Generative AI implied; the order references generative AI programs like ChatGPT generally | Warning | None | Oct 2026 |
| Wilcox v. Gingrinch | Ind. Ct. App. Court of Appeals of Indiana | Jan 2026 | Generative AI (presumed; not acknowledged) | Warning | None | Oct 2026 |
| Greene v. GSK PLC | W.D. Wash. U.S. District Court, Western District of Washington | Jan 2026 | Unspecified generative AI | Warning | None (warning only; the Court reserved Rule 11 sanctions for any future filing providing 'authority to the Court that does not actually exist') | May 2026 |
| Mims v. Brown | W.D. Wis. U.S. District Court, Western District of Wisconsin | Jan 2026 | ChatGPT (identified in PDF metadata of the plaintiff's filings) | Warning | None | Oct 2026 |
| Matter of Bramstedt Surgical Inc. | GAO U.S. Government Accountability Office | Jan 2026 | Unspecified generative AI | Warning | None | May 2026 |
| Cassata v. Michael Macrina Architect, P.C. | Sup. Ct., Suffolk County, N.Y. Supreme Court of New York, Suffolk County | Jan 2026 | Unspecified generative AI | Court sanction | $10,000 | May 2026 |
| Lifetime Well LLC v. IBSpot.com Inc. | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Jan 2026 | Lexis+ AI and LexisNexis Protégé | Court sanction | $4,000 | Apr 2026 |
| Future Field Solutions, LLC v. Van Norstrand | D. Md. U.S. District Court, District of Maryland | Jan 2026 | Unspecified generative AI | Other | None | Sep 2026 |
| Tolbert v. The State | Ga. Ct. App. Court of Appeals of Georgia | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Kaufman v. Upton | D. Mass. U.S. District Court, District of Massachusetts | Jan 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| That Xiong v. Minga Wofford | E.D. Cal. U.S. District Court, Eastern District of California | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Button v. Jimison (Jan. 20, 2026 order) | W.D. Wash. U.S. District Court, Western District of Washington | Jan 2026 | Generative AI inferred from the citation pattern; specific tool not identified on the record | Court sanction | Not stated | Sep 2026 |
| Medical Buyers Group v. Pence | M.D. Ga. U.S. District Court, Middle District of Georgia, Athens Division | Jan 2026 | Unspecified generative AI | Court sanction | $10,000 | May 2026 |
| Osborne Properties Limited Partnership v. Mohamed | Minn. Dist. Ct. (Hennepin Cnty.) Minnesota District Court, County of Hennepin, Fourth Judicial District | Jan 2026 | Unidentified (the order finds that counsel "twice submitted a fake, hallucinated case" and discusses attorneys' use of AI generally, but does not find that he used AI or name a tool) | Court sanction | $5,000 penalty on the attorney personally, not his client (payable at $500 a month under a May 5, 2026 amendment); false citations struck and inaccurate ones corrected; the court to inform the Lawyers Professional Responsibility Board | Sep 2026 |
| Yue v. Reaction Labs, LLC | W.D. Tex. U.S. District Court, Western District of Texas, Austin Division | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Alzado-Lotz v. Bock | D. Colo. U.S. District Court, District of Colorado | Jan 2026 | Implied (undisclosed; fabricated citation hallmarks) | Other | None | May 2026 |
| Hodges v. Meridian Waste Acquisitions, LLC (consolidated with Rieske v. Accounting Fulfillment Services, LLC) | M.D. Fla. U.S. District Court, Middle District of Florida, Jacksonville Division | Jan 2026 | Unspecified generative AI | Court sanction | $7,000 | Apr 2026 |
| Lepp v. Mallett | E.D. Mich. U.S. District Court, Eastern District of Michigan | Jan 2026 | OpenAI ChatGPT-4o (Plaintiff disclosed using ChatGPT-4o to produce an 'AI Legal Analysis Report' attached as an exhibit) | Other | None | May 2026 |
| Tafah v. Lake Village Townhomes | D. Md. U.S. District Court, District of Maryland | Jan 2026 | Generative AI implied; the order references a fabricated case-law citation characteristic of AI hallucination output | Warning | None | Oct 2026 |
| Tiffany K. v. Commissioner of Social Security | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Jan 2026 | Unidentified (the order says the apparently non-existent Fleck v. Comm'r of Soc. Sec. citation was "likely caused by use of generative artificial intelligence (AI)"; it makes no finding of AI use and names no tool) | Warning | None | Sep 2026 |
| Corst v. Mushailov | N.Y. Civ. Ct., Kings Cty. Civil Court of the City of New York, Kings County | Jan 2026 | Unidentified (the court wrote in a footnote that "these 'hallucinated' cases appear to have been generated with the use of an artificial intelligence program," while noting counsel's letter did not specifically acknowledge it; no tool is named) | Other | None | Sep 2026 |
| North Atlantic Operating Company, Inc., et al. v. Indiana Import, LLC, et al. | S.D. Ind. U.S. District Court, Southern District of Indiana | Jan 2026 | Not named in the order; the order does not mention artificial intelligence, and AI use is an inference drawn by the Charlotin tracker, not a court finding | Court sanction | Not stated | Oct 2026 |
| Boyd v. Lee | Md. Ct. Spec. App. Appellate Court of Maryland | Jan 2026 | Unspecified generative AI | Other | None | Sep 2026 |
| Lopez Hernandez v. Lundy | E.D. Cal. U.S. District Court, Eastern District of California | Jan 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| Kjoller v. Superior Court of Nevada County (People real party in interest) | Cal. California Supreme Court (directing Third District Court of Appeal) | Jan 2026 | not named on the record | Pending | Pending | Apr 2026 |
| Saber v. Navy Federal Credit Union | Pa. Super. Ct. Pennsylvania Superior Court | Jan 2026 | Generative AI (unspecified) | Other | None | May 2026 |
| Viken v. Schuelke | Minn. Dist. Ct. (Hennepin Cnty.) Minnesota District Court, County of Hennepin, Fourth Judicial District | Jan 2026 | "Lexis Assist" (per the order, counsel said at the hearing that he had relied upon "Lexis Assist"; the order does not describe the product or attribute the quotations to AI) | Pending | Pending | Sep 2026 |
| Russel Williams Home Services LLC v. Minleon International (USA) Limited LLC | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Jan 2026 | Unspecified generative AI | Other | None | Oct 2026 |
| Young v. City of Memphis | W.D. Tenn. U.S. District Court for the Western District of Tennessee | Jan 2026 | Microsoft Teams 'Read AI' transcription / recap feature | Other | None | May 2026 |
| Bacurin v. Bacurin | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Northeast District (Alhambra Courthouse) | Jan 2026 | Unidentified (the order finds cited pages and cases that do not exist and a quotation absent from the cited case, but it does not mention AI or name a tool) | Other | None | Sep 2026 |
| Collins v. Nova Association Management Partners LLC | W.D. Wash. U.S. District Court, Western District of Washington | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Heiting v. I Am Beyond LLC | Cal. Super. Ct. (L.A. County) Superior Court of California, County of Los Angeles | Jan 2026 | Not identified (the ruling says it is "likely" the briefing "was influenced by hallucinations that are inherent in the use of artificial intelligence") | Warning | None | Sep 2026 |
| Mavy v. Commissioner of Social Security Administration | D. Ariz. U.S. District Court, District of Arizona | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Doe v. United States (D.N.J. 2026) | D.N.J. U.S. District Court, District of New Jersey | Jan 2026 | Unspecified generative AI | Warning | None (Rule 11 caution in footnote 3 of dismissal order; complaint dismissed without prejudice under 28 U.S.C. § 1915(e)(2) on separate Rule 8 / failure-to-state-a-claim grounds with leave to amend) | May 2026 |
| Gharavi v. Google LLC | N.D. Cal. U.S. District Court, Northern District of California | Jan 2026 | Not mentioned in the order (the error came from Bloomberg Law search results) | Other | None | Sep 2026 |
| Wurtenberg v. The City of New York | N.Y. Sup. Ct. Supreme Court of the State of New York, New York County | Jan 2026 | Not determined (the court found the opposition's defects "consistent with the misuse of a generative artificial intelligence program") | Warning | None | Sep 2026 |
| Garibay-Robledo v. Noem | N.D. Tex. U.S. District Court, Northern District of Texas, Abilene Division | Jan 2026 | Not mentioned in either order (counsel said the non-existent case "was obtained from a Facebook comment") | Court sanction | Not stated | Sep 2026 |
| Hayes v. Chipotle Mexican Grill, LLC | M.D. Fla. U.S. District Court, Middle District of Florida | Jan 2026 | Unidentified (the court found it 'likely' Hayes used 'automated, artificial intelligence tools'; no specific tool named) | Warning | None | May 2026 |
| Deutsche Bank National Trust Co. v. LeTennier | N.Y. App. Div. 3d Dep't New York Supreme Court, Appellate Division, Third Department | Jan 2026 | Unspecified generative AI | Court sanction | $10,000 | May 2026 |
| Hollinger v. Enlisted Association of the National Guard of the United States | E.D. Va. U.S. District Court, Eastern District of Virginia, Alexandria Division | Jan 2026 | Unidentified (the order states that Hollinger "admitted he used artificial intelligence ('AI') to generate legal authority"; no tool is named) | Court sanction | Not stated | Sep 2026 |
| McPhaul v. College Hills OPCO, LLC | D. Kan. U.S. District Court, District of Kansas | Jan 2026 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Ayatollah Hylton v. Chivone Janee Hylton | S.D. Fla. U.S. District Court, Southern District of Florida | Jan 2026 | Unidentified (the court found a non-existent case citation in a pro se filing; it did not attribute the fabrication to AI, and named no tool) | Warning | None | May 2026 |
| Allen v. Experian Information Solutions, Inc. | D. Idaho U.S. District Court, District of Idaho | Jan 2026 | Implied (court referenced 'mistaken reliance upon artificial intelligence for legal research') | Warning | None | Oct 2026 |
| Washburn v. Houston | Ariz. Ct. App. Arizona Court of Appeals, Division One | Jan 2026 | None stated in the decision (it calls the quotations and record cites "hallucinated" but does not mention AI) | Other | No monetary sanction; decision forwarded to the State Bar of Arizona to review whether counsel violated any rule of professional conduct | Sep 2026 |
| Burnett v. The City of New York | N.Y. Sup. Ct., N.Y. Cnty. Supreme Court of the State of New York, New York County | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Hildebrandt v. siParadigm LLC | D.N.J. U.S. District Court, District of New Jersey | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Sevilla v. Ross | D.S.C. U.S. District Court, District of South Carolina | Dec 2025 | Generative AI implied; the order's footnote describes "hallmarks of motions created using artificial intelligence or found on the internet" | Warning | None | Oct 2026 |
| Jones v. Experian Information Solutions, Inc. (E.D. Mich.) | E.D. Mich. U.S. District Court, Eastern District of Michigan | Dec 2025 | Generative AI (specific tool not identified on the record; court inferred AI use from misuse of a Sixth Circuit case in arbitration briefing) | Warning | None | Oct 2026 |
| Labatt USA Operating Co., LLC v. Friends Beverage Group, LLC | N.Y. Sup. Ct., N.Y. Cnty. Supreme Court of New York, New York County | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| M.T. Real Estate Investment Inc. v. Servis One, Inc., et al. | D. Nev. U.S. District Court, District of Nevada | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Pauliah v. University of Mississippi Medical Center | S.D. Miss. U.S. District Court, Southern District of Mississippi, Northern Division | Dec 2025 | Unspecified generative AI | Court sanction | $5,000 | May 2026 |
| Ringer v. Bank of America, N.A. | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Dec 2025 | Unspecified generative AI | Court sanction | $1,500 | Apr 2026 |
| Silverberg v. Bonomo | D. Nev. U.S. District Court, District of Nevada | Dec 2025 | Generative AI (court referenced potential AI misuse; specific tool not identified) | Warning | None | Oct 2026 |
| Cherleatha B. v. Bisignano | D.S.C. U.S. District Court, District of South Carolina | Dec 2025 | Generative AI implied; the order describes generative AI programs that "hallucinate" nonexistent cases | Warning | None | Oct 2026 |
| In re S.A., D.H., and B.M., Minors | Ill. App. 2d Dist. Appellate Court of Illinois, Second District | Dec 2025 | Unspecified generative AI | Other | None | Sep 2026 |
| Ng v. AmGuard Insurance Company | S.D.N.Y. U.S. District Court, Southern District of New York | Dec 2025 | Implied (court suspected AI hallucination; specific tool not identified) | Court sanction | Not stated | May 2026 |
| Allen v. Amazon | N.D. Tex. U.S. District Court, Northern District of Texas | Dec 2025 | Unidentified generative AI (Allen did not dispute using AI; no specific tool named) | Warning | None | May 2026 |
| Leber v. Bryan Medical Center | D. Neb. U.S. District Court, District of Nebraska | Dec 2025 | Implied (court characterized cited case as 'a hallucination of artificial intelligence') | Warning | None | Oct 2026 |
| Donovan v. Clark County Assessor | Ind. Tax Ct. Indiana Tax Court | Dec 2025 | Generative artificial intelligence (specific tool not identified); use confirmed at oral argument | Warning | None | Oct 2026 |
| Billups v. Louisville Municipal School District | N.D. Miss. U.S. District Court, Northern District of Mississippi, Aberdeen Division | Dec 2025 | Grok | Court sanction | Not stated | Apr 2026 |
| Disability Rights Mississippi v. Palmer Home for Children | N.D. Miss. U.S. District Court for the Northern District of Mississippi, Aberdeen Division | Dec 2025 | AI use suspected but contested; counsel denied AI use and attributed errors to an 'internal reference document' (Microsoft OneNote screenshots) and copy-paste errors | Court sanction | $20,883.10 in attorney's fees and costs, plus mandatory 3-hour Mississippi CLE on hallucinatory AI citations | May 2026 |
| Fantini v. Westrock Co. | D.N.J. U.S. District Court, District of New Jersey | Dec 2025 | Unspecified generative AI | Warning | None (Rule 11 reminder in footnote 5 of summary-judgment opinion; sanctions reserved for any future failure to conduct 'reasonable inquiry') | May 2026 |
| Patrick Joseph Groulx v. CSL Limited | Mich. Ct. App. Michigan Court of Appeals | Dec 2025 | Unidentified (the order cites two non-existent cases but does not mention AI or name a tool) | Court sanction | Appeal dismissed (the order does not label the dismissal a sanction); appellees' sanctions request held "not properly presented," without prejudice to a separate motion within 21 days | Sep 2026 |
| Menk v. The Mitre Corporation | D. Md. U.S. District Court, District of Maryland | Dec 2025 | ChatGPT (per counsel's own explanation, as recounted in the order: he used ChatGPT, "a generative artificial intelligence ('AI') chatbot," for preliminary research, and it supplied the citation) | Warning | None | Sep 2026 |
| Simpson v. Portfolio Recovery Associates, LLC | W.D. Va. U.S. District Court, Western District of Virginia | Dec 2025 | Unspecified generative AI (court referenced 'generative artificial intelligence' generally; no specific tool identified on the record) | Warning | None | Oct 2026 |
| Gerou v. George | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Dec 2025 | Generative AI implied; the order discusses AI-generated fabricated citations generally | Warning | None | Oct 2026 |
| Lafayette v. Abrami | Vt. Super. Vermont Superior Court, Lamoille Unit, Civil Division | Dec 2025 | Unidentified generative AI 'software' (the order describes plaintiff's reliance on 'artificial intelligence software' for legal research; specific tool not named) | Court sanction | $7,360.96 in attorney's fees and costs ($7,346.56 fees + $14.40 costs) under Vermont's anti-SLAPP statute, plus a pre-filing injunction limiting plaintiff to attorney-represented filings or pre-clearance by the assigned superior court judge | May 2026 |
| Wireless Investors LLC v. Semtech Incorporated, et al. | D. Ariz. U.S. District Court, District of Arizona | Dec 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Zhang v. National Public Radio, Inc. | D.D.C. U.S. District Court, District of Columbia | Dec 2025 | Generative AI implied; the orders identify nonexistent and misrepresented citations characteristic of AI hallucination output | Court sanction | $1,000 (final amount; reduced from initial sanction figure following sealed in-camera hearing) | Sep 2026 |
| Friend v. Serpa | Fla. 4th DCA Florida Fourth District Court of Appeal | Dec 2025 | Generative AI (court addressed use of 'artificial intelligence' explicitly; specific tool not named) | Warning | None | Sep 2026 |
| Halpern v. Federal Reserve Bank of New York | N.D. Ill. U.S. District Court, Northern District of Illinois, Western Division | Dec 2025 | Unspecified generative AI (court flagged "hallucinated by Artificial Intelligence" as the likely source) | Warning | None | Sep 2026 |
| L.A. Housing Outreach, LLC v. Medoff | Cal. Ct. App. California Court of Appeal, Second District, Division 4 | Dec 2025 | Unspecified generative AI | Court sanction | $5,070 | May 2026 |
| Angelica E. Cruz et al. v. United States of America | C.D. Cal. U.S. District Court, Central District of California | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Dorsey v. Jones | Del. Ch. Chancery Court of Delaware | Dec 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Holmes Family Trust v. Multnomah County Assessor | Or. Tax Ct. Oregon Tax Court, Magistrate Division | Dec 2025 | Generative artificial intelligence (specific product not identified by court) | Warning | None | Oct 2026 |
| In re Zimmer M/L Taper Hip Prosthesis (McMillian v. Zimmer US, Inc.) | S.D.N.Y. U.S. District Court, Southern District of New York | Dec 2025 | Unspecified generative AI | Court sanction | $9,000 | Apr 2026 |
| PRM Group, Inc. v. Paralegal Bootcamp LLC | D. Md. U.S. District Court, District of Maryland | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Taylor v. Prince George's County, Maryland | D. Md. U.S. District Court, District of Maryland | Dec 2025 | Unspecified (the magistrate judge noted the citation errors are the type generative AI produces but said it was unclear whether AI or another circumstance caused them) | Other | None | May 2026 |
| Braica v. Frankowski | D. Conn. U.S. District Court, District of Connecticut | Dec 2025 | Unspecified generative AI | Court sanction | Admonition + strike of Plaintiff's Response (ECF No. 30) and Sur-Reply (ECF No. 32) from the record without leave to amend; future sanctions (including dismissal of the case with prejudice) reserved for any further AI-generated hallucinations in any subsequent filing | May 2026 |
| Gardner v. Combs | D.N.J. U.S. District Court, District of New Jersey | Dec 2025 | Unspecified generative AI | Court sanction | $6,000 | May 2026 |
| Harvey v. Torrent Leasing & U.S. Bank | D. Nev. U.S. District Court, District of Nevada | Dec 2025 | ChatGPT (court named ChatGPT specifically as exemplar of generative AI that "may hallucinate") | Other | None | May 2026 |
| Jeter v. ADUSA Transportation LLC | D.S.C. U.S. District Court, District of South Carolina | Dec 2025 | Generative AI implied; the magistrate's R&R discusses AI use generally | Warning | None | Oct 2026 |
| Maturin v. T-Mobile USA, Inc. | D.N.M. U.S. District Court, District of New Mexico | Dec 2025 | Generative AI implied; the magistrate's recommendation discusses AI use generally; the district judge's adoption order requires future AI-disclosure certifications | Court sanction | $8,640 (recommended; final amount to be set on supplemental affidavit) | May 2026 |
| Williams v. Canavan | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Dec 2025 | Unspecified generative AI; the order references 'cut-and-paste AI outputs' generally | Warning | None | Oct 2026 |
| Couvrette v. Wisnovsky | D. Or. U.S. District Court for the District of Oregon, Medford Division | Dec 2025 | Generative AI (unspecified; not identified by the court) | Court sanction | $110,204.38 total. Lead counsel Brigandi: $15,500 Clerk sanction + $80,498.72 (85% of defendants' $94,704.38 amended fee award) = $95,998.72. Local counsel Murphy: $14,205.66 (15% of fee award) for willful violation of LR 83-3. | Sep 2026 |
| N.Z. v. Fenix International Limited | C.D. Cal. U.S. District Court, Central District of California | Dec 2025 | ChatGPT | Court sanction | $13,000 | Apr 2026 |
| Sanchez v. Chedraui USA, Inc. | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Central District (Spring Street Courthouse) | Dec 2025 | Unidentified (the court "could not locate" the cited case and issued an order to show cause about "a fabricated case citation," but neither order mentions AI or names a tool) | Other | None | Sep 2026 |
| Russell v. Mells | Fla. 2d DCA District Court of Appeal of Florida, Second District | Dec 2025 | Unspecified generative AI | Other | None | Oct 2026 |
| Sharky's Sports Bar v. Village of Mt. Morris, Illinois | N.D. Ill. U.S. District Court, Northern District of Illinois, Western Division | Dec 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| South Side Area School District v. Pennsylvania Human Relations Commission | Pa. Commw. Ct. Pennsylvania Commonwealth Court | Dec 2025 | Unidentified (the court's January 12, 2026 order lists quotations that "could not be located in the cited case" and does not mention AI; AI questioning at oral argument is reported only in news coverage) | Pending | Pending | Sep 2026 |
| Dusablon v. Gibbs | S.D.N.Y. U.S. District Court, Southern District of New York | Dec 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Lin v. Leal | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Northeast District (Alhambra Courthouse) | Dec 2025 | Unidentified (the orders describe "fake and/or improper" case citations, and the October 23 order states that one cited case "does not exist," but neither mentions AI or names a tool) | Court sanction | $500, payable to the Superior Court of California, County of Los Angeles, by January 12, 2026 (Code Civ. Proc. 177.5, for violation of Code Civ. Proc. 128.7(b)(2)) | Sep 2026 |
| Dodge v. FirstService Residential Arizona LLC | D. Ariz. U.S. District Court, District of Arizona | Dec 2025 | Federally Lawyer (counsel testified it is "an add-on to the enterprise version of ChatGPT") | Other | None | Sep 2026 |
| Browne v. Ciobanu | 7th Cir. U.S. Court of Appeals for the Seventh Circuit | Dec 2025 | Generative AI inferred from R&G AI Court Order Tracker classification; the published opinion itself does not mention AI, ChatGPT, generative tools, or hallucinations. The AI-conduct claim rests on the appellant's underlying briefs rather than on findings in the panel order. | Other | None | Sep 2026 |
| In re Nupeutics Natural, Inc.; Gladstone v. Peatross | Bankr. S.D. Cal. United States Bankruptcy Court, Southern District of California | Dec 2025 | Unspecified generative AI | Court sanction | $950 | Apr 2026 |
| Mullins v. Duquesne University of the Holy Spirit | W.D. Pa. U.S. District Court, Western District of Pennsylvania | Dec 2025 | Not named in the order striking the brief; plaintiff's subsequent re-filed reply identified ChatGPT and Claude | Court sanction | Not stated | May 2026 |
| Jordan v. Chicago Housing Authority | Cook County, Ill. Circuit Court of Cook County, Illinois, County Department, Law Division | Dec 2025 | ChatGPT (used by one partner, Danielle Malaty, per her statements to the court; the order finds the balance of the false quotations and holdings "are not explained by an attorney's misuse of a new technology") | Court sanction | $59,500 total ($10,000 against attorney Larry Mason; $49,500 against Goldberg Segalla LLP) | Sep 2026 |
| Wade v. TrainCareConsult, Inc. | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Northeast District (Alhambra Courthouse) | Dec 2025 | Unidentified (the court recited the defendant's request for sanctions based on "apparent signs that the opposition contains artificial intelligence 'hallucinations'" and quoted Noland v. Land of the Free on citations "whether provided by generative AI or any other source," but made no finding that AI was used; no tool is named) | Court sanction | $500, payable to counsel for defendant by January 5, 2026 | Sep 2026 |
| Black Oak Capital BOCA, LLC v. Paul Evans, LLC | D. Utah U.S. District Court, District of Utah | Dec 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Dorsey v. Ponce | N.D. Ill. U.S. District Court, Northern District of Illinois | Dec 2025 | Unidentified (the court suspected an artificial intelligence tool but named none; Dorsey disclosed no tool) | Warning | None | May 2026 |
| Hill v. Oklahoma County Criminal Justice Authority | W.D. Okla. U.S. District Court, Western District of Oklahoma | Dec 2025 | ChatGPT | Court sanction | Defendants' reasonable attorneys' fees and costs for hearing attendance (amount to be determined) | Apr 2026 |
| Jason M. Hatfield, P.A. v. Pirani | W.D. Ark. U.S. District Court, Western District of Arkansas | Dec 2025 | Unspecified (Pirani admitted using artificial intelligence; the orders name no tool) | Court sanction | $1,000 fine to the Clerk of the Court | Sep 2026 |
| Moore v. City of Del City | 10th Cir. U.S. Court of Appeals for the Tenth Circuit | Dec 2025 | Generative AI (no specific tool named in the order) | Court sanction | Not stated | May 2026 |
| Ringo v. Colquhoun Design Studio, LLC | Or. Ct. App. Oregon Court of Appeals | Dec 2025 | Generative AI (unspecified; court did not name a specific tool) | Court sanction | $2,000 | Apr 2026 |
| United States v. Boehm | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Dec 2025 | Unspecified generative AI; the court ordered prospective disclosure of the specific tool used | Warning | None | Sep 2026 |
| Harris v. Pinnacle Bank | N.D. Miss. U.S. District Court, Northern District of Mississippi, Oxford Division | Dec 2025 | Not mentioned in the order (the order refers only to "fictitious legal authorities"; the court's later May 7, 2026 opinion says the show cause issued after the court learned the filing "likely contained AI-generated legal citations") | Warning | None | Sep 2026 |
| Jarrus v. Governor of Michigan | E.D. Mich. U.S. District Court, Eastern District of Michigan | Dec 2025 | ChatGPT (Plaintiff Michael Jarrus admitted using ChatGPT Plus, $20/month subscription) | Court sanction | $600 ($300 per Plaintiff) | May 2026 |
| Johnson v. Insight Global, LLC | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Dec 2025 | Not found (the report records the defendant's point that the plaintiff "appears to rely upon citations to non-existent caselaw, which may be the result of generative artificial intelligence"; the court made no AI finding and named no tool) | Warning | None | Sep 2026 |
| Magee v. New Balance Athletics, Inc. | E.D. Ark. U.S. District Court, Eastern District of Arkansas | Dec 2025 | Generative AI; the tool is not named, but Magee acknowledged on the record that he prepared the response using generative AI | Court sanction | Not stated | Oct 2026 |
| Bey v. Glass | M.D. Fla. U.S. District Court, Middle District of Florida | Dec 2025 | Unidentified (the court believed a fabricated citation was 'possibly caused by the use of Artificial Intelligence'; no tool named) | Warning | None | May 2026 |
| Shayan v. Shakib | Cal. Ct. App. California Court of Appeal, Second Appellate District, Division One | Dec 2025 | Unspecified generative AI | Court sanction | $7,500 | May 2026 |
| The Doc App, Inc. d/b/a My Florida Green v. Leafwell, Inc. | M.D. Fla. U.S. District Court, Middle District of Florida, Fort Myers Division | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Jesse Andre v. Warden, FCI Danbury | D. Conn. U.S. District Court, District of Connecticut | Nov 2025 | Generative artificial intelligence (Petitioner admitted to 'heavy' reliance on AI; tool not specifically identified by name on the record; drafting service was 'Nuline Legal' / Alan Adamz, help@nulinelegal.com) | Court sanction | Not stated | Sep 2026 |
| Associated Builders and Contractors, Inc., Eastern Pennsylvania Chapter v. Bucks County Community College | Pa. Commw. Ct. Commonwealth Court of Pennsylvania | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | Sep 2026 |
| Mills v. Rocket Mortgage LLC | W.D. La. U.S. District Court for the Western District of Louisiana | Nov 2025 | Unidentified generative AI (the magistrate found that plaintiffs 'likely used generative artificial intelligence (GenAI) to assist in research and failed to check whether the GenAI-generated content was accurate'; specific tool not on the record) | Warning | None | Oct 2026 |
| Pletcher v. Village of Libertyville Police Pension Board | Ill. App. 2d Dist. Appellate Court of Illinois, Second District | Nov 2025 | Unspecified generative AI (admitted by appellant at oral argument) | Court sanction | Not stated | May 2026 |
| Dubinin v. Papazian | S.D. Fla. U.S. District Court, Southern District of Florida | Nov 2025 | Unspecified generative AI | Court sanction | $4,030.90 | Apr 2026 |
| Clayman v. Bessant | S.D. Fla. U.S. District Court, Southern District of Florida | Nov 2025 | Generative AI (court found plaintiff's citation 'United States v. Bovio, 708 F. Supp. 2d 579 (E.D.N.Y. 2010)' was 'an AI-generated hallucination and not an actual case'; specific tool not named) | Court sanction | Not stated | May 2026 |
| Kilinc v. PMMUE Eduservices Private Limited | S.D.N.Y. U.S. District Court, Southern District of New York | Nov 2025 | Unspecified generative AI | Other | None | Oct 2026 |
| Raymond Alan Shields v. First Financial Corporation | Tenn. Cir. Ct. (Davidson Cnty.) Sixth Circuit Court for Davidson County, Tennessee | Nov 2025 | Not determined (the order says the errors are "characteristic of Artificial Intelligence use" and does not find that AI was used) | Warning | None | Sep 2026 |
| Buchanan v. Vuori, Inc. | N.D. Cal. U.S. District Court, Northern District of California | Nov 2025 | ChatGPT, Claude, Clear Brief, Lexis, Westlaw (six AI tools per attorney's response) | Court sanction | $250 | Apr 2026 |
| Evans v. Robertson | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Nov 2025 | Unidentified (the order sanctions both parties for factitious citations but does not mention AI; the magistrate judge's September 25, 2025 order had called earlier factitious citations "presumably a product of using artificial intelligence (AI) software") | Court sanction | Revocation of both parties' Pro Se Electronic Document Upload privileges for the case (filings by mail or hand delivery only); no monetary sanction; seven previously stricken briefs to remain stricken; warning that each future brief with factitious citations would draw a one-hundred-dollar fine | Sep 2026 |
| In re Jackson Hospital & Clinic, Inc. | Bankr. M.D. Ala. U.S. Bankruptcy Court, Middle District of Alabama | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Nuvola, LLC v. Wright | Minn. Dist. Ct. (Hennepin Cnty.) Minnesota District Court, County of Hennepin, Fourth Judicial District | Nov 2025 | Unidentified generative AI program (counsel "admitted that he used generative artificial intelligence (AI) to draft his memorandum") | Court sanction | $1,000 | Sep 2026 |
| Ekeocha v. U.S. Department of State | D.D.C. U.S. District Court for the District of Columbia | Nov 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Mareiorozyan v. Automobili Lamborghini America, LLC | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Northwest District (Van Nuys Courthouse East) | Nov 2025 | Unidentified (the court wrote that Midway "persuasively argues" and makes "a compelling argument" that the citation came from counsel's improper use of artificial intelligence, but it made no finding and warned counsel only "[i]f the nonexistent citation was the result of counsel using AI"; no tool is named) | Warning | None | Sep 2026 |
| Paredes Guevara v. A&P Restaurant Corp. | S.D.N.Y. U.S. District Court, Southern District of New York | Nov 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Moorehead v. Goodwill Industries of Northeast Texas | E.D. Tex. U.S. District Court, Eastern District of Texas | Nov 2025 | Unidentified (the court suspected the citations were 'hallucinations by generative artificial intelligence'; no specific tool named) | Warning | None | May 2026 |
| Nellum v. Credit Acceptance Corporation | S.D. Ind. U.S. District Court, Southern District of Indiana | Nov 2025 | Generative artificial intelligence inferred from sur-reply citation pattern; specific tool not identified | Warning | None | Oct 2026 |
| Cojom v. Roblen, LLC | D. Conn. U.S. District Court, District of Connecticut | Nov 2025 | Descrybe.AI | Court sanction | $500 | Apr 2026 |
| Gittemeier v. Liberty Mutual Personal Insurance Company | E.D. Mo. U.S. District Court, Eastern District of Missouri | Nov 2025 | Unspecified generative AI | Court sanction | $1,000 | Apr 2026 |
| Mattson v. Rosebud Electric Cooperative | D.S.D. U.S. District Court, District of South Dakota, Central Division | Nov 2025 | Implied (court found 'the formatting of the brief, which seemed to suggest the use of generative AI') | Other | None | May 2026 |
| Neal v. Frayer | D. Md. U.S. District Court, District of Maryland | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Schlichter v. Kennedy | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division Two | Nov 2025 | Unspecified generative AI | Court sanction | $1,750 | May 2026 |
| Lewis v. Eagle County Government | D. Colo. U.S. District Court, District of Colorado | Nov 2025 | Unspecified (the court found the citations 'bear the hallmarks of generative artificial intelligence'; counsel denied using AI) | Court sanction | $28,000 total: $3,000 Rule 11 sanction payable to the Court, plus $25,000 in defense attorney's fees under 28 U.S.C. § 1927 (stipulated amount, awarded Dec. 16, 2025), both joint and several against counsel and her firm | Sep 2026 |
| Montoya Cabanas v. Bondi | S.D. Tex. U.S. District Court, Southern District of Texas, Houston Division | Nov 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Matter of Matos | N.Y. App. Div. 1st Dep't New York Supreme Court, Appellate Division, First Department | Nov 2025 | Unspecified generative AI | Bar discipline | Not stated | May 2026 |
| Richard LaRoche v. Darla Sterett (LaRoche) | Vt. Vermont Supreme Court | Nov 2025 | Unspecified generative AI (described in the order as an "AI helper") | Court sanction | Not stated | Apr 2026 |
| Master Textile Mills, Ltd. v. RSA Global Logistics, LLC | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Nov 2025 | Suspected, not found (the court said a miscited local rule "creates suspicion that counsel is relying heavily on generative artificial intelligence and not properly checking the citations it produces"; no tool is named and no AI use is found) | Warning | None | Sep 2026 |
| Bey v. Apple Inc. | M.D. Fla. U.S. District Court, Middle District of Florida, Tampa Division | Nov 2025 | Unidentified (Apple's reply said Bey "either used artificial intelligence or fabricated case law"; the court noted Bey did not deny it and warned against "[f]urther use of artificial intelligence resulting in hallucinated authority"; no tool is named) | Warning | None | Sep 2026 |
| Shelton v. Parkland Health | N.D. Tex. U.S. District Court, Northern District of Texas | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Swincher v. Fay Servicing, LLC | W.D. Ky. U.S. District Court, Western District of Kentucky | Nov 2025 | Generative AI implied; the order references a fabricated case-law citation characteristic of AI hallucination output | Other | None | May 2026 |
| United States v. Czartorski | W.D. Ky. U.S. District Court, Western District of Kentucky, Louisville Division | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| David v. George Chiala Farms, Inc. | N.D. Cal. U.S. District Court, Northern District of California | Nov 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| In the Interest of M. O. W. | Tex. App.—Austin Court of Appeals of Texas, Austin | Nov 2025 | Unspecified generative AI | Other | None | Sep 2026 |
| Parker v. Costco Wholesale Corp. | W.D. Wash. U.S. District Court, Western District of Washington | Nov 2025 | Callidus AI | Court sanction | $6,200 (approx.) | Apr 2026 |
| Rivera-Carrasquillo v. United States | D.P.R. U.S. District Court, District of Puerto Rico | Nov 2025 | Unidentified (the order says counsel cited caselaw "in a misleading fashion" and quoted a non-existent passage, but does not mention AI or name a tool) | Other | None | Sep 2026 |
| Thomas v. Delaware Technical & Cmty. Coll. | D. Del. U.S. District Court, District of Delaware | Nov 2025 | Implied (specific tool not identified on the available record) | Warning | None at this stage (Rule 11 motion for costs and fees denied without prejudice to renew once the merits of the case are resolved) | May 2026 |
| Jamison Warfield v. W.N. Morehouse Truck Line, Inc. | E.D. Tenn. U.S. District Court, Eastern District of Tennessee, Northeastern Division | Nov 2025 | Unidentified (the order only recounts the defendant's assertion of incorrect and nonexistent citations; it does not mention AI or name a tool) | Other | None | Sep 2026 |
| Hernandez v. Kunes | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Nov 2025 | Examples named in the order: OpenAI ChatGPT and Google Gemini | Other | None | May 2026 |
| In re: Deborah Ann Mitchell | Bankr. D. Conn. U.S. Bankruptcy Court, District of Connecticut, New Haven Division | Nov 2025 | Generative artificial intelligence (Debtor admitted at the October 22, 2025 hearing that she used an A.I. program 'for formatting' her filings; ECF No. 36 specifically attests it was prepared with A.I. assistance; tool not specifically identified by name on the record) | Other | None | May 2026 |
| Logan v. LVNV Funding, LLC | D. Utah U.S. District Court, District of Utah | Nov 2025 | Generative AI generally; specific tool not named in the order | Warning | None | Oct 2026 |
| Lowrey v. City of Rio Rancho | D.N.M. U.S. District Court, District of New Mexico | Nov 2025 | Generative AI implied; the order references AI tools producing hallucinated citations | Warning | None | Oct 2026 |
| Smart v. The Professional Group | E.D. Mich. U.S. District Court, Eastern District of Michigan | Nov 2025 | Generative AI (specific tool not identified; use inferred from filing patterns matching prior AI-generated ADA notices observed in other cases) | Warning | None | Sep 2026 |
| Borsody v. Frontier Heritage Communities | D. Kan. U.S. District Court for the District of Kansas | Nov 2025 | Unidentified generative AI (the court inferred AI use from a nonexistent case citation; Ms. Borsody did not identify a specific tool) | Warning | None | Oct 2026 |
| Glass v. Foley & Lardner LLP | W.D. Wis. U.S. District Court, Western District of Wisconsin | Nov 2025 | Generative AI implied; the order describes AI tools that "hallucinate" false case citations | Warning | None | Oct 2026 |
| Kheir v. Titan Team LLC, The Money Source Inc., and Auction.com | Bankr. S.D. Tex. U.S. Bankruptcy Court, Southern District of Texas, Houston Division | Nov 2025 | ChatGPT | Court sanction | Not stated | Apr 2026 |
| Kluwe v. Huntington Beach Union High School District | C.D. Cal. U.S. District Court, Central District of California | Nov 2025 | Unidentified generative AI | Court sanction | $2,000 (counsel sanction; Rule 11 and inherent power) | May 2026 |
| Creech v. City of Raleigh | N.C. Ct. App. North Carolina Court of Appeals | Nov 2025 | Vincent AI (per counsel's sworn statement filed with the Notice of Correction; the court's order and opinion do not mention AI) | Court sanction | Cost of printing the amended brief taxed to counsel personally (the order states no amount) | Sep 2026 |
| Isaacs v. Novartis Pharmaceuticals Corporation | D.N.J. U.S. District Court, District of New Jersey | Nov 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Mezu v. Mezu | Md. App. Ct. Appellate Court of Maryland | Nov 2025 | ChatGPT, VLex, CourtListener, CaseMine, Justia | Other | None | Oct 2026 |
| Wheat v. Vichie | Sup. Ct. N.Y. Cty. New York Supreme Court, New York County | Nov 2025 | Unidentified (the court noted the fabrications could be 'the result of reliance on AI or otherwise'; no specific tool named) | Warning | None | May 2026 |
| Iowa Supreme Court Attorney Disciplinary Board v. Pazdernik | Iowa Iowa Supreme Court | Oct 2025 | ChatGPT | Bar discipline | Not stated | Sep 2026 |
| County of Los Angeles v. Niblett | Cal. Ct. App. California Court of Appeal, Second District, Division One | Oct 2025 | Unspecified generative AI | Court sanction | $5,000 against attorney Robert W. Lucas individually, payable to the clerk of the Second District within 30 days after remittitur; opinion and order sent to the State Bar under Bus. & Prof. Code § 6086.7(a)(3) | Sep 2026 |
| Safe Choice, LLC v. City of Cleveland | N.D. Ohio U.S. District Court, Northern District of Ohio | Oct 2025 | Unspecified generative AI | Court sanction | $7,500 | May 2026 |
| Sauls v. Pierce County | W.D. Wash. U.S. District Court, Western District of Washington | Oct 2025 | Generative AI inferred from the citation pattern; specific tool not identified on the record | Warning | None | Oct 2026 |
| Warner v. Gilbarco, Inc. | E.D. Mich. U.S. District Court, Eastern District of Michigan | Oct 2025 | Generative AI (specific tool not identified; use inferred by the court from misrepresented citations and patterns observed in other recent filings) | Warning | None | Oct 2026 |
| Goldman v. Arizona Board of Regents | D. Ariz. U.S. District Court, District of Arizona | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Wilson v. KIPP Texas, Inc. | N.D. Tex. U.S. District Court for the Northern District of Texas, Dallas Division | Oct 2025 | ChatGPT | Court sanction | Not stated | Apr 2026 |
| Boston v. Williams (In re Loletha Hale, Esq.) | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Villasenor v. Ralphs Grocery Company | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, South Central District (Compton Courthouse) | Oct 2025 | Unidentified (the ruling says a cited case "does not exist" but does not mention AI or name a tool) | Other | None | Sep 2026 |
| Green Building Initiative, Inc. v. Green Globe International, Inc. | D. Or. U.S. District Court for the District of Oregon | Oct 2025 | Microsoft Copilot | Other | None | Apr 2026 |
| Crowder v. Yussman | Ky. Ct. App. Kentucky Court of Appeals | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | Sep 2026 |
| Crudup v. City of Atlanta | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Oct 2025 | Not mentioned (the order concludes that at least four cases cited by the pro se plaintiff "likely do not exist" but does not mention AI) | Other | None | Sep 2026 |
| Appeals of Huffman Construction, LLC | ASBCA Armed Services Board of Contract Appeals | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | Sep 2026 |
| In re: Sanctions Order of Kenney | La. App. 5 Cir. Court of Appeal of Louisiana, Fifth Circuit | Oct 2025 | ChatGPT, Microsoft Copilot, and Google | Court sanction | $1,368 | Sep 2026 |
| Alexandria Jones v. District of Columbia Office of Unified Communications | D.D.C. U.S. District Court, District of Columbia | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Mattox v. Product Innovations Research, LLC | E.D. Okla. U.S. District Court, Eastern District of Oklahoma | Oct 2025 | ChatGPT | Court sanction | $6,000 in individual fines ($3,000 / $2,000 / $1,000) plus $23,495.90 in joint and several attorney's fees and costs | Sep 2026 |
| N-Bar Trade, Inc. v. Amazon.com Services LLC | D.D.C. U.S. District Court, District of Columbia | Oct 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| University Mall, LLC v. Okorie | S.D. Miss. U.S. District Court, Southern District of Mississippi | Oct 2025 | Implied (specific tool not identified; court found Okorie uses AI to generate his pleadings) | Court sanction | Not stated | May 2026 |
| Arch Insurance Company v. A3 Development, LLC | S.D. Fla. U.S. District Court, Southern District of Florida | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Chastain v. City of Kansas City | Mo. Ct. App. W.D. Missouri Court of Appeals, Western District | Oct 2025 | Google 'AI Overview' search summaries (cited by appellant in lieu of legal authority) | Other | None | May 2026 |
| Rimu Capital Ltd. v. Ader | S.D.N.Y. U.S. District Court, Southern District of New York | Oct 2025 | Unidentified (defense counsel told the court the research was, he was informed, done by another attorney his client had hired, and that AI is something he has "never used and never will use"; the court made no finding about AI) | Warning | None | Sep 2026 |
| Button v. Jimison (Oct. 17, 2025 order) | W.D. Wash. U.S. District Court, Western District of Washington | Oct 2025 | Generative AI inferred from the citation pattern; specific tool not identified on the record | Other | None | May 2026 |
| Mundy v. Clickstop, Inc. | Neb. Dist. Ct. (Douglas Cnty.) District Court of Nebraska, Douglas County | Oct 2025 | Unspecified generative AI (counsel "stated he had utilized generative artificial intelligence (“AI”) in his court filings") | Court sanction | $2,000 | Sep 2026 |
| Tippecanoe County Assessor v. Goergen | Ind. Tax Ct. Indiana Tax Court | Oct 2025 | Generative artificial intelligence inferred from a fictitious case citation; specific tool not identified | Warning | None | Oct 2026 |
| Serafin Tristan v. United States Department of State | E.D. Mo. U.S. District Court, Eastern District of Missouri, Eastern Division | Oct 2025 | Generative AI (implied; the court noted citations to nonexistent cases and a citation that resolved to a different and unrelated case, with the Damien Charlotin tracker categorizing the conduct as 'Implied' AI use; specific tool not identified on the record) | Warning | None | Oct 2026 |
| Smith v. Trump | D.D.C. U.S. District Court, District of Columbia | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Manisero v. Bradshaw | S.D. Fla. U.S. District Court, Southern District of Florida | Oct 2025 | Not found (the sheriff's reply said several of the plaintiff's case citations were incorrect, "which implies the inappropriate use of Artificial Intelligence"; the court made no finding and addressed its notice "[t]o the extent that Plaintiff is using AI"; no tool is named) | Warning | None | Sep 2026 |
| Puig Valdes v. All3Media America, LLC | L.A. Super. Ct. Los Angeles County Superior Court | Oct 2025 | ChatGPT | Other | None | Oct 2026 |
| Reed v. Community Health Care | W.D. Wash. U.S. District Court, Western District of Washington | Oct 2025 | Generative AI inferred from the citation pattern; specific tool not identified on the record | Warning | None | Sep 2026 |
| Stephanie Tovar v. United Pacific; Everest Premier Insurance Co. | California (WCAB) California Workers' Compensation Appeals Board | Oct 2025 | Unspecified generative AI (suspected; not confirmed in the order) | Court sanction | Up to $2,500 (Notice of Intention; final sanctions pending response) | Apr 2026 |
| Oneto v. Watson | N.D. Cal. U.S. District Court, Northern District of California | Oct 2025 | Google AI Overview | Court sanction | $1,000 | May 2026 |
| United States v. Glennie Antonio McGee | S.D. Ala. U.S. District Court, Southern District of Alabama | Oct 2025 | Ghostwriter Legal | Court sanction | $5,000 | Apr 2026 |
| Jakes v. Youngblood | W.D. Pa. U.S. District Court, Western District of Pennsylvania | Oct 2025 | Unspecified generative AI | Court sanction | $5,000 | Apr 2026 |
| Support Community, Inc. v. MPH International LLC | N.D. Cal. U.S. District Court, Northern District of California | Oct 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Smith v. Athena Construction Group, Inc. | D.D.C. U.S. District Court, District of Columbia | Oct 2025 | Lexis+ AI (with Grammarly and ProWritingAid also used by counsel) | Court sanction | Not stated | Apr 2026 |
| Tovar v. American Automatic Fire Suppression, Inc. | Cal. Super. Ct. (San Diego Cnty.) Superior Court of California, County of San Diego | Oct 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Basko v. Civic Sherman LLC | N.Y. Sup. Ct. New York Supreme Court, Kings County | Oct 2025 | Unidentified (the decision says the reply papers contain "what appears to be a fictitious citation" and quotes Mata v. Avianca on "fake opinions," but does not mention AI or name a tool) | Pending | None yet; the parties were directed to appear on October 1, 2025 for a hearing on "appropriate costs and/or sanctions" under 22 NYCRR 130-1.1 | Sep 2026 |
| Lafontant v. Coolidge-CLK St. Germane, LLC | E.D. La. U.S. District Court, Eastern District of Louisiana | Oct 2025 | Unspecified generative AI | Court sanction | $1,000 | Apr 2026 |
| People v. Alvarez | Cal. Ct. App. California Court of Appeal, Fourth Appellate District, Division One | Oct 2025 | Unspecified generative AI | Court sanction | $1,500 | Apr 2026 |
| Ader v. Ader | N.Y. Sup. Ct. (N.Y. Cnty.) Supreme Court of New York, New York County | Oct 2025 | not named in order | Court sanction | Not stated | May 2026 |
| In the Interest of R.A. | Iowa Ct. App. Iowa Court of Appeals | Oct 2025 | Unspecified generative AI | Court sanction | $150 | May 2026 |
| In re Estate of Kuerschner (Kuerschner v. Kuerschner) | Ariz. Ct. App. Arizona Court of Appeals, Division One | Sep 2025 | Unidentified (the decision says a cited case appears not to exist but does not mention AI) | Other | None for the citation errors; the court declined to find waiver and reached the merits. Appellate fees and costs were awarded to the estate under A.R.S. 14-1105 for her continued pursuit of meritless claims, not for the citations | Sep 2026 |
| Kertesz v. Colony Tire Corp. et al. | D.N.J. U.S. District Court, District of New Jersey | Sep 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Khoury et al. v. Intermountain Health Care, Inc. | D. Utah U.S. District Court, District of Utah | Sep 2025 | ChatGPT | Other | None | May 2026 |
| Tomlin v. State of New Mexico | D.N.M. U.S. District Court, District of New Mexico | Sep 2025 | ChatGPT or similar generative AI; the order names ChatGPT explicitly as a possible source | Warning | None | Oct 2026 |
| Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner (reinstatement) | Iowa Sup. Ct. Iowa Supreme Court | Sep 2025 | Unidentified (the Board's motion to strike describes "what appears to be at least one AI-generated citation"; no tool is named, and the docket comments on the court's orders do not mention AI; the order texts are not public) | Other | None | Sep 2026 |
| Lofton v. Bolin Grove Farms, LLC | Cir. Ct. DeSoto Cty., Miss. Circuit Court of DeSoto County, Mississippi | Sep 2025 | An AI research tool the attorney associated with Fastcase (the order records her citing "FastCase, a paid service rendered by the Mississippi Bar," as a source of the citations; she also cited general internet research) | Court sanction | $7,472 in attorneys' fees and costs to Briggs Equipment, Inc., payable by counsel personally (a separate $37,584.91 fee award in the same order was for discovery abuse) | Sep 2026 |
| Pennantia, LLC v. Rose Cay Maritime, LLC | S.D.N.Y. U.S. District Court, Southern District of New York | Sep 2025 | Unspecified generative AI | Other | None | Oct 2026 |
| Evans v. Robertson | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Sep 2025 | Presumed, tool not identified (the magistrate judge describes the factitious citations as "presumably a product of using artificial intelligence (AI) software") | Warning | None | Sep 2026 |
| Eric Andrew Perez v. Dr. Neil C. Evans | S.D.N.Y. U.S. District Court, Southern District of New York | Sep 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Shaporov v. PIPPD P.O. Matthew Levine | D.N.J. U.S. District Court, District of New Jersey | Sep 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Kenisha Black v. Mississippi Department of Rehabilitation Services & Howard | S.D. Miss. U.S. District Court, Southern District of Mississippi | Sep 2025 | Not identified (counsel "admits that her opening memorandum and reply brief both contained false AI-generated content") | Other | None | Sep 2026 |
| Lipe v. Albuquerque Public Schools | D.N.M. U.S. District Court, District of New Mexico | Sep 2025 | Unspecified generative AI | Court sanction | $3,000 | Apr 2026 |
| Stern v. Molina (In re Molina) | E.D.N.Y. Bankr. U.S. Bankruptcy Court, Eastern District of New York | Sep 2025 | Implied (court could not locate cited cases; AI hallucination suspected) | Court sanction | Not stated | Oct 2026 |
| Vision Management Group, LLC v. Constant Aviation, LLC | N.D. Ohio U.S. District Court, Northern District of Ohio | Sep 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Ali v. IT People Corporation, Inc. | E.D. Mich. U.S. District Court, Eastern District of Michigan | Sep 2025 | Generative AI (specific tool not identified on the record; Plaintiff admitted excessive reliance on AI-generated documents) | Court sanction | $600 | May 2026 |
| Bryant v. Pottsgrove School District | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Sep 2025 | OpenAI ChatGPT (named in the opinion) | Other | None | Oct 2026 |
| Cingel v. Ferreri | Ind. Ct. App. Court of Appeals of Indiana | Sep 2025 | Generative artificial intelligence inferred from citation pattern; specific tool not identified | Other | None | May 2026 |
| Gibralter, LLC v. DMS Flowers, LLC | E.D. Cal. U.S. District Court, Eastern District of California | Sep 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| United States v. Malik | D. Md. U.S. District Court, District of Maryland | Sep 2025 | Generative AI implied; the order references a fabricated legal-norm citation characteristic of AI hallucination output | Warning | None | Oct 2026 |
| OTG New York, Inc. v. Ottogi America, Inc. | D.N.J. U.S. District Court, District of New Jersey | Sep 2025 | Unspecified generative AI | Court sanction | $3,000 | May 2026 |
| Pelishek v. City of Sheboygan | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Sep 2025 | Westlaw Quick Check | Court sanction | $4,500 | Apr 2026 |
| Jeramiah Brown v. Fat Dough Incorporated, d/b/a Domino's Pizza | N.D.N.Y. U.S. District Court, Northern District of New York | Sep 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Latasha Hill v. Auto Club Family Insurance Company | S.D. Miss. U.S. District Court, Southern District of Mississippi | Sep 2025 | Unidentified (the court was 'concerned' the citations were generative-AI output; no tool named) | Warning | None | May 2026 |
| Facey v. Fisher | N.Y. Sup. Ct. New York Supreme Court, New York County | Sep 2025 | not named (court directed counsel to file affirmation disclosing AI/chatbot use) | Court sanction | Not stated | May 2026 |
| Yi-Sheng Fang, et al. v. Hechalou US LLC, et al. | C.D. Cal. U.S. District Court, Central District of California | Sep 2025 | Unspecified generative AI | Court sanction | $2,418.50 | May 2026 |
| Noland v. Land of the Free, L.P. | Cal. Ct. App. California Court of Appeal, Second District, Division Three | Sep 2025 | ChatGPT, Claude, Gemini, and Grok (counsel admitted the fabrications resulted from his reliance on "generative AI sources such as ChatGPT, Claude, Gemini, and Grok") | Court sanction | $10,000 payable to the clerk of the Court of Appeal; opinion forwarded to the State Bar under Bus. & Prof. Code § 6086.7(a)(3); counsel to serve the opinion on his client and certify service | Sep 2026 |
| Mid-America Apartment Communities, Inc. v. Philipson | W.D. Tenn. U.S. District Court for the Western District of Tennessee, Western Division | Sep 2025 | Suspected generative AI, tool not named (the court "suspects" the citation and quote were "likely created by a generative artificial intelligence tool," noting Philipson had said at earlier status conferences that he uses AI to generate his filings' content) | Warning | None | Sep 2026 |
| United States v. Brewer | M.D. Fla. U.S. District Court, Middle District of Florida, Orlando Division | Sep 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Robinson v. Oglala Sioux Tribe | W.D. Okla. U.S. District Court, Western District of Oklahoma | Sep 2025 | Generative AI (specific tool not identified on the record; Plaintiff's filings repeatedly contained non-existent and misrepresented legal authority) | Court sanction | Dismissal with prejudice | May 2026 |
| Tercero v. Sacramento Logistics, LLC | E.D. Cal. U.S. District Court, Eastern District of California | Sep 2025 | Unspecified generative AI | Court sanction | $1,500 | Apr 2026 |
| Brooks v. Patel | Minn. Dist. Ct. (Hennepin Cnty.) Minnesota District Court, County of Hennepin, Fourth Judicial District | Sep 2025 | VLex Fastcase (per the order, counsel admitted in writing that he "failed to properly confirm the accuracy of the Hallock [sic] citation through VLex Fastcase," which the court describes as "the AI research tool he used in drafting his motion") | Court sanction | $5,000 penalty on the attorney, not his client, under Minn. R. Civ. P. 11.03 and Minn. Stat. § 549.211, subd. 5; summary judgment briefing struck; summary judgment motion denied; referral to the Lawyers Professional Responsibility Board | Sep 2026 |
| CommNV, LLC v. Uprise, LLC | Nev. 2d Jud. Dist. Ct. (Washoe County) Second Judicial District Court of the State of Nevada, Washoe County | Sep 2025 | ChatGPT | Court sanction | $5,000 | Apr 2026 |
| Hill v. Workday, Inc. | N.D. Cal. U.S. District Court, Northern District of California | Sep 2025 | CoCounsel | Court sanction | Not stated | Apr 2026 |
| Thompson v. Commissioner of Social Security Administration | D. Ariz. U.S. District Court, District of Arizona | Sep 2025 | Unidentified (the order does not find AI use in this case; it notes that counsel was sanctioned in a separate case for a brief with deficiencies "including those consistent with artificial intelligence generated hallucinations") | Other | None | Sep 2026 |
| In re Whitehall Pharmacy LLC | Bankr. E.D. Ark. U.S. Bankruptcy Court, Eastern District of Arkansas | Sep 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Lewis v. Entergy Mississippi, LLC | S.D. Miss. U.S. District Court, Southern District of Mississippi, Northern Division | Sep 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Davis v. Marion County Superior Court Juvenile Detention Center | S.D. Ind. U.S. District Court, Southern District of Indiana, Indianapolis Division | Sep 2025 | Unspecified generative AI | Court sanction | $7,500 | May 2026 |
| Clerk of the Court and Comptroller for the 13th Judicial Circuit, Hillsborough County, Florida v. Rangel | Fla. 2d DCA District Court of Appeal of Florida, Second District | Aug 2025 | Unspecified generative AI | Court sanction | Not stated | Oct 2026 |
| Allbaugh v. University of Scranton | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Aug 2025 | Not named in the August 28 sanction order; the court's underlying standing civil practice order on generative AI references ChatGPT and Bard as examples | Court sanction | $1,000 | May 2026 |
| Lee v. R&R Home Care, Inc. | E.D. La. U.S. District Court, Eastern District of Louisiana | Aug 2025 | Google Gemini | Court sanction | $1,000 | Apr 2026 |
| Multiphone Latin America Inc. v. Millicom International Cellular S.A. | S.D. Fla. U.S. District Court, Southern District of Florida | Aug 2025 | Unspecified generative AI | Other | None | Oct 2026 |
| Robert Thackston v. Daniel P. Driscoll, Secretary of the Army | W.D. Tex. U.S. District Court, Western District of Texas, San Antonio Division | Aug 2025 | Unidentified generative AI (the magistrate judge inferred from the citations that counsel "likely used generative artificial intelligence . . . to assist in his research," and from repeated phrasing that he "may have utilized GenAI to write some or all of his brief"; no tool is named) | Other | None imposed; the Report and Recommendation asks the District Court to consider Rule 11(c) sanctions | Sep 2026 |
| In re Richburg | Bankr. D.S.C. U.S. Bankruptcy Court for the District of South Carolina | Aug 2025 | Microsoft Copilot | Court sanction | Not stated | Apr 2026 |
| Antonia Meza Roman v. County of Los Angeles | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, South Central District (Compton Courthouse) | Aug 2025 | Unidentified (the minute order says two cited cases do not exist and that others do not stand for the cited propositions, but it does not mention AI or name a tool) | Warning | None | Sep 2026 |
| Betancourt Gómez v. Colegio de Profesionales de la Enfermería de Puerto Rico | P.R. T.P.I. (San Juan) Tribunal de Primera Instancia, Sala Superior de San Juan (Puerto Rico) | Aug 2025 | Not identified (counsel did not expressly admit using AI; the court found the errors consistent with unreviewed output of technological tools) | Court sanction | $1,000 | Sep 2026 |
| Chenco Engineering & Consulting GmbH v. Do-Fluoride New Materials Co. Ltd. | D. Idaho U.S. District Court, District of Idaho | Aug 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| In re R.L. | Ill. App. 4th Dist. Appellate Court of Illinois, Fourth District | Aug 2025 | Not found by the court (the order makes no finding about AI; AI appears only in the title of a news article it cites) | Other | None | Sep 2026 |
| Lahti v. Consensys Software Inc. | S.D. Ohio U.S. District Court, Southern District of Ohio | Aug 2025 | Unidentified generative AI (the court found fictitious citations with 'the hallmarks of text generated by a large language model'; no specific tool named) | Warning | None | May 2026 |
| Williams v. Kirch | Ind. Ct. App. Court of Appeals of Indiana | Aug 2025 | Generative artificial intelligence inferred from fictitious case citations; specific tool not identified | Warning | None | Oct 2026 |
| Xu v. Nasser (In re Nasser) | Bankr. E.D. Mich. United States Bankruptcy Court, Eastern District of Michigan, Southern Division | Aug 2025 | Unspecified generative AI (suspected; not confirmed by counsel) | Court sanction | Not stated | Apr 2026 |
| Monster Energy Co. v. Owoc | S.D. Fla. U.S. District Court, Southern District of Florida | Aug 2025 | Generative AI (Owoc acknowledged at the Show Cause hearing that AI generated the fake citations; specific tool not named) | Court sanction | Non-monetary: 10 hours community service within 20 days of the order; prospective AI disclosure and certification requirement for all future filings in this matter; no monetary sanction | May 2026 |
| Nora v. M & A Transport, Inc. | E.D. La. U.S. District Court, Eastern District of Louisiana | Aug 2025 | Westlaw Precision (AI-assisted research) | Court sanction | $1,000 | Apr 2026 |
| Chavez-DeRemer v. NAB, LLC | D. Nev. U.S. District Court, District of Nevada | Aug 2025 | Generative AI (court referenced ChatGPT and similar tools as exemplars) | Warning | None | Oct 2026 |
| Hall v. The Academy Charter School | E.D.N.Y. U.S. District Court, Eastern District of New York | Aug 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| In re S.M., a Minor | Ill. App. Ct. (4th Dist.) Illinois Appellate Court, Fourth District | Aug 2025 | Not mentioned in the order | Court sanction | $1,000 | Sep 2026 |
| Pineda v. Campos | Ariz. Ct. App. Arizona Court of Appeals, Division One | Aug 2025 | Unidentified (the decision finds fabricated quotations and citations whose reporter pages point to unrelated opinions, but does not mention AI or name a tool) | Court sanction | Not stated | Sep 2026 |
| Gezalayan v. BMW North American, LLC | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, Central District (Stanley Mosk Courthouse) | Aug 2025 | Unidentified (the minute order calls the citation a "non-existent case" but does not mention AI or name a tool) | Warning | None | Sep 2026 |
| In re A.S. | Ill. App. (4th) Appellate Court of Illinois, Fourth District | Aug 2025 | AI use inferred, not admitted (the court found AI use "a reasonable conclusion based upon our review of the briefing, the response to the rule to show cause, and Attorney Panichi's past conduct"; no tool named) | Court sanction | $1,000 monetary sanction payable to the clerk of the Fourth District Appellate Court | Sep 2026 |
| Hunter Tellez v. Proiettii | E.D. Cal. U.S. District Court, Eastern District of California | Aug 2025 | Implied (court found fabricated and misrepresented case law; specific tool not identified) | Court sanction | Not stated | May 2026 |
| Advani v. Appellate Term, 2nd Judicial Department | S.D.N.Y. U.S. District Court, Southern District of New York | Aug 2025 | Implied (court suspected AI-generated fabrications; specific tool not identified) | Court sanction | Not stated | May 2026 |
| J.D. v. Superior Court | Cal. Ct. App. Court of Appeal of California, Fifth Appellate District | Jul 2025 | Unidentified (the opinion flags a statutory quotation it could not verify but does not mention AI or name a tool) | Warning | None | Sep 2026 |
| Mitra Mirage v. Costco Wholesale Corporation | C.D. Cal. U.S. District Court, Central District of California | Jul 2025 | Unidentified (the order says "[t]o the extent that Plaintiff has relied on artificial intelligence," Plaintiff did not comply with the judge's AI disclosure standing order; it does not find that AI was used or name a tool) | Warning | None | Sep 2026 |
| Coronavirus Reporter Corporation v. Apple Inc. | N.D. Cal. U.S. District Court, Northern District of California | Jul 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Axis Dynamics, Inc. v. Knox County, Tennessee | E.D. Tenn. U.S. District Court, Eastern District of Tennessee, at Knoxville | Jul 2025 | Unidentified (the court said it "cannot say whether this is the product of a lack of diligence, an irresponsible use of generative artificial intelligence, or an intentional attempt to mislead the Court"; no tool is named) | Warning | None | Sep 2026 |
| Idehen v. Stoute-Phillip | N.Y. Civ. Ct., Queens Cty. Civil Court of the City of New York, Queens County | Jul 2025 | Microsoft Copilot | Court sanction | $1,000 | May 2026 |
| Robbins v. Martin Law Firm, P.L. | M.D. Fla. U.S. District Court, Middle District of Florida, Fort Myers Division | Jul 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC and AP Electric, Inc. v. Oakland Automation, LLC (consolidated) | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Jul 2025 | Generative AI / Large language models (court characterized the citations as 'false citations generated by so-called artificial intelligence (AI)'; specific tool not named on the record) | Court sanction | $1,485 to defense counsel | May 2026 |
| Pop Top Corp. v. Rakuten Kobo Inc. | N.D. Cal. U.S. District Court, Northern District of California | Jul 2025 | ChatGPT (implied) | Warning | None | Oct 2026 |
| Elizondo v. City of Laredo | S.D. Tex. U.S. District Court, Southern District of Texas, Laredo Division | Jul 2025 | Unspecified generative AI | Court sanction | $2,500 | Apr 2026 |
| In re CorMedix Inc. Securities Litigation | D.N.J. U.S. District Court, District of New Jersey | Jul 2025 | ChatGPT, used by a law-school intern (temporary assistant) in chambers without authorization or disclosure, per Judge Neals's October 20, 2025 letter to Senator Grassley | Other | None | May 2026 |
| Johnson v. Dunn | N.D. Ala. U.S. District Court, Northern District of Alabama | Jul 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Vita Law Offices, P.C. v. Lockridge Grindal Nauen P.L.L.P. | D. Mass. U.S. District Court, District of Massachusetts | Jul 2025 | Microsoft Copilot | Court sanction | Not stated | Apr 2026 |
| In re Baby Boy and A.H., Minors | Ill. App. Ct. (4th Dist.) Appellate Court of Illinois, Fourth District | Jul 2025 | Unspecified generative AI | Court sanction | $7,925.62 | May 2026 |
| Rotharmel v. Dauphin County Children & Youth Services | M.D. Pa. U.S. District Court, Middle District of Pennsylvania | Jul 2025 | Callidus AI | Warning | None | Oct 2026 |
| In re Marla C. Martin | Bankr. N.D. Ill. U.S. Bankruptcy Court, Northern District of Illinois, Eastern Division | Jul 2025 | ChatGPT | Court sanction | $5,500 | Apr 2026 |
| Parrish v. Miller | S.D. Ind. U.S. District Court, Southern District of Indiana | Jul 2025 | Implied (court did not affirmatively identify AI use; cited cases either egregiously miscited or do not exist) | Other | None | May 2026 |
| Augustin v. Formula 3 Brooklyn Inc. | Sup. Ct. Kings Cty. New York Supreme Court, Kings County | Jul 2025 | Unidentified (the court found the defendants used 'artificial intelligence software'; no specific tool named) | Warning | None | May 2026 |
| ByoPlanet International, LLC v. Johansson | S.D. Fla. U.S. District Court, Southern District of Florida | Jul 2025 | ChatGPT | Court sanction | $85,567.75 | Sep 2026 |
| Jackson v. Auto-Owners Insurance Company | M.D. Ga. U.S. District Court, Middle District of Georgia | Jul 2025 | Unspecified generative AI | Court sanction | $1,000 | Apr 2026 |
| Crespo v. Tesla, Inc. | S.D. Fla. U.S. District Court, Southern District of Florida | Jul 2025 | Generative AI (plaintiff used AI to generate discovery motions per the docketed Order to Show Cause; specific tool not named on the docket text we have) | Court sanction | Not stated | May 2026 |
| Kessler v. City of Atwater | E.D. Cal. U.S. District Court, Eastern District of California | Jul 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Student Doe v. Noem | D.D.C. U.S. District Court, District of Columbia | Jul 2025 | ChatGPT (counsel's response to the show-cause order states that she "used ChatGPT to assist with initial research and the framing of the issues presented"; the court's July 10, 2025 minute order admonishes counsel "about her use of AI technology") | Warning | None | Sep 2026 |
| Kaur v. Desso | N.D.N.Y. U.S. District Court, Northern District of New York | Jul 2025 | Claude Sonnet 4 | Court sanction | $1,000 | Apr 2026 |
| Coomer v. Lindell | D. Colo. U.S. District Court, District of Colorado | Jul 2025 | Microsoft Copilot, Westlaw AI, Google Gemini, Grok, Claude, ChatGPT, Perplexity | Court sanction | $6,000 | Apr 2026 |
| Gamble v. Gamble (R&G caption: Smith v. Gamble) | Ohio Ct. App. (12th Dist.) Ohio Court of Appeals, Twelfth Appellate District | Jul 2025 | Unidentified generative AI (the court referenced a federal case involving 'a brief generated by artificial intelligence' as comparable; the appellee's specific tool was not identified on the record) | Court sanction | Not stated | May 2026 |
| Tijerino v. Spotify USA Inc. | E.D. La. U.S. District Court for the Eastern District of Louisiana | Jul 2025 | Unidentified live AI assistant (the order describes an 'artificial intelligence program' Mr. Tijerino used to respond during a meet-and-confer; the specific tool is not named) | Other | None | May 2026 |
| Sharita Hill v. State of Oklahoma ex rel. Oklahoma Medical Marijuana Authority | W.D. Okla. U.S. District Court, Western District of Oklahoma | Jul 2025 | Implied (not disclosed by counsel) | Warning | None (admonishment only) | Oct 2026 |
| Tyrone Walker v. Juliane Pierre | Mass. App. Ct. Appeals Court of Massachusetts | Jul 2025 | Unidentified (the decision says only that the struck portions of the brief "included citations to nonexistent cases"; it does not mention AI or name a tool) | Other | None | Sep 2026 |
| Shahid v. Esaam | Ga. Ct. App. Georgia Court of Appeals, First Division | Jun 2025 | AI (unspecified) | Court sanction | $2,500 | May 2026 |
| Twist It Up, Inc. v. Annie International, Inc. | C.D. Cal. U.S. District Court, Central District of California | Jun 2025 | Unidentified (the June 27, 2025 minutes refer to "invalid case citations generated by the use of an artificial intelligence application") | Court sanction | $500 | Sep 2026 |
| Dastou v. Holmes | Middlesex Sup. Ct. Massachusetts Superior Court, Middlesex County | Jun 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Romero v. Goldman Sachs Bank USA | S.D.N.Y. U.S. District Court, Southern District of New York | Jun 2025 | Implied (court suspected AI-generated citations; specific tool not identified) | Court sanction | Not stated | May 2026 |
| Allen v. Mercedes-Benz USA, LLC | E.D. Cal. U.S. District Court, Eastern District of California | Jun 2025 | Unidentified (the order finds fabricated quotations but does not attribute them to AI or name a tool) | Other | None | Oct 2026 |
| Mintvest Capital, LTD v. NYDIG Trust Company | D.P.R. U.S. District Court, District of Puerto Rico | Jun 2025 | Claude | Court sanction | Opposing counsel's fees (amount not yet quantified) | May 2026 |
| Taylor v. Cooper Power & Lighting Corp. | E.D.N.Y. U.S. District Court, Eastern District of New York | Jun 2025 | Unidentified (the show-cause order could not locate the case and the report and recommendation records counsel's admission that he fabricated it; neither mentions AI or names a tool; counsel called the citation a "placeholder" in a draft) | Other | None | Sep 2026 |
| Rochon-Eidsvig v. JGB Collateral, LLC | Tex. App. (5th Dist.) Texas Court of Appeals, Fifth District at Dallas | Jun 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Jon H. v. Lydia M. | W. Va. Fam. Ct. (Kanawha County) Family Court of Kanawha County, West Virginia (as described by the Intermediate Court of Appeals of West Virginia) | Jun 2025 | Unidentified (counsel reported that her staff used 'artificial intelligence' to draft a motion; no tool is named) | Other | None | Sep 2026 |
| Powhatan County School Board v. Skinger | E.D. Va. U.S. District Court, Eastern District of Virginia, Richmond Division | Jun 2025 | ChatGPT | Court sanction | Not stated | May 2026 |
| Flowz Digital LLC v. Dalal | C.D. Cal. U.S. District Court, Central District of California | May 2025 | Unspecified generative AI | Court sanction | $3,500 | Oct 2026 |
| Roark v. American Airlines Group, Inc. | D. Conn. U.S. District Court, District of Connecticut | May 2025 | Generative artificial intelligence (Court found 'misstatements throughout the filing are likely the product of generative artificial intelligence'; specific tool not identified by name on the record) | Warning | None | Oct 2026 |
| Woodmen of the World Life Insurance Society v. Hale | W.D. Tex. U.S. District Court, Western District of Texas, San Antonio Division | May 2025 | Generative AI (tool not specified by court; pro se defendant's filing relied on what the court characterized as an 'artificial intelligence (AI) tool') | Other | None | May 2026 |
| Delano Crossing 2016, LLC v. County of Wright | Minn. Tax Ct. Minnesota Tax Court, Regular Division | May 2025 | Unspecified generative AI | Other | None | Sep 2026 |
| Mid Central Operating Engineers Health and Welfare Fund v. HoosierVac LLC | S.D. Ind. U.S. District Court for the Southern District of Indiana, Terre Haute Division | May 2025 | Generative AI (counsel admitted relying on "programs utilizing generative artificial intelligence" to draft the briefs; no product named) | Court sanction | $6,000 | Sep 2026 |
| Concord Music Group, Inc. v. Anthropic PBC | N.D. Cal. U.S. District Court, Northern District of California | May 2025 | Claude.ai | Court sanction | Not stated | Apr 2026 |
| Dupont v. Town of Wales | Mass. Super. Ct. Massachusetts Superior Court, Hampden County | May 2025 | Unidentified (the decision says only that the court "was unable to find" a cited case and that "[t]he citation is incorrect, or the case does not exist"; it does not mention AI or name a tool) | Other | None | Sep 2026 |
| Garner v. Kadince | Utah Ct. App. Utah Court of Appeals | May 2025 | ChatGPT | Court sanction | Attorney fees + client fee refund + $1,000 to access-to-justice nonprofit | Sep 2026 |
| Versant Funding LLC v. Teras Breakbulk Ocean Navigation Enterprises LLC | S.D. Fla. U.S. District Court, Southern District of Florida | May 2025 | Unspecified generative AI | Court sanction | $1,500 | Apr 2026 |
| Volker v. Nygaard | N.D. Dist. Ct. North Dakota District Court, East Central Judicial District (Cass County) | May 2025 | Unidentified (the North Dakota Supreme Court describes the citations as AI-generated but names no tool) | Court sanction | Not stated | Oct 2026 |
| Gjovik v. Apple Inc. | N.D. Cal. U.S. District Court, Northern District of California | May 2025 | Unidentified generative AI | Court sanction | Not stated | May 2026 |
| Benshoof v. Chin | W.D. Wash. U.S. District Court, Western District of Washington | May 2025 | Generative AI inferred from the citation pattern; specific tool not identified on the record | Warning | None | Oct 2026 |
| Keaau Development Partnership LLC v. Lawrence | Haw. Ct. App. Intermediate Court of Appeals of the State of Hawai'i | May 2025 | Unspecified generative AI | Court sanction | $100 | May 2026 |
| United States v. Burke | M.D. Fla. U.S. District Court, Middle District of Florida, Tampa Division | May 2025 | Westlaw (including AI features and Quick Check) and ChatGPT Pro (GPT-4.5) Deep Research | Court sanction | Not stated | Apr 2026 |
| Ramirez v. Humala | E.D.N.Y. U.S. District Court, Eastern District of New York | May 2025 | Unspecified generative AI | Court sanction | $1,000 | Apr 2026 |
| Newbern v. DeSoto County School District | N.D. Miss. U.S. District Court, Northern District of Mississippi | May 2025 | Generative AI implied; the order references fabricated case-law citations characteristic of AI hallucination output | Court sanction | Not stated | May 2026 |
| In re Daniel M. Risis | Bankr. D.N.J. U.S. Bankruptcy Court, District of New Jersey | May 2025 | 'Kasper' (a self-built AI assistant created by the debtor) | Other | None monetary (16 AI-signed submissions struck and denied without prejudice; AI agent representation denied; motion to integrate AI agent with PACER denied) | May 2026 |
| Lacey v. State Farm General Insurance Co. | C.D. Cal. U.S. District Court, Central District of California | May 2025 | CoCounsel, Westlaw Precision, and Google Gemini (multi-tool workflow) | Court sanction | $31,100 | May 2026 |
| Wilt v. Department of the Navy | E.D. Tex. U.S. District Court, Eastern District of Texas, Tyler Division | May 2025 | Suspected (the court said the two cases "appear to have been generated by artificial intelligence"; no tool identified and no admission) | Warning | None | Sep 2026 |
| Benjamin v. Costco Wholesale Corp. | E.D.N.Y. U.S. District Court, Eastern District of New York | Apr 2025 | ChatOn | Court sanction | $1,000 | May 2026 |
| Truong v. Flint Hills Resources, LLC | S.D. Tex. U.S. District Court, Southern District of Texas, Corpus Christi Division | Apr 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Bevins v. Colgate-Palmolive Co. | E.D. Pa. U.S. District Court, Eastern District of Pennsylvania | Apr 2025 | Unspecified generative AI | Court sanction | Not stated | Apr 2026 |
| Puerto Rico Soccer League NFP, Corp. v. Federacion Puertorriquena de Futbol | D.P.R. U.S. District Court, District of Puerto Rico | Apr 2025 | Unspecified generative AI | Court sanction | $24,492.10 in defendants' attorneys' fees and costs for responding to the four defective filings (amount set Sept. 23, 2025, ECF 283) | Sep 2026 |
| Aponte v. Portfolio Recovery Associates, LLC | E.D. Ark. U.S. District Court, Eastern District of Arkansas | Apr 2025 | Generative AI implied; the show-cause order addressed defective citations characteristic of AI hallucination output | Other | None | May 2026 |
| Gordon v. Wells Fargo Bank N.A. Inc. | M.D. Ga. U.S. District Court, Middle District of Georgia, Macon Division | Apr 2025 | Unspecified generative AI | Warning | None (Rule 11 warning; sanctions reserved for any future failure to comply with Rule 11 obligations, with the Court noting Plaintiff 'may incur a substantial penalty' including attorney's-fees award, monetary penalty to the Court, or dismissal of the lawsuit) | May 2026 |
| Daniel Jaiyong An v. Archblock, Inc. | Del. Ch. Delaware Court of Chancery | Apr 2025 | Suspected generative AI, tool not identified (the letter opinion says "I suspect that the petitioner used generative artificial intelligence"; the accompanying Order says the false citations were "presumably due to his use of generative artificial intelligence") | Warning | None | Sep 2026 |
| Dehghani v. Castro | D.N.M. U.S. District Court, District of New Mexico | Apr 2025 | Unspecified generative AI | Court sanction | $1,500 | Apr 2026 |
| Boggess v. Chamness | E.D. Tex. U.S. District Court, Eastern District of Texas, Tyler Division | Apr 2025 | Suspected (the court said the citation "was likely generated via artificial intelligence"; no tool identified and no admission) | Warning | None | Sep 2026 |
| Enzor / Bennington DUI matter (Vt.) | Vt. Super. Ct. Vermont Superior Court, Bennington Unit (Criminal Division) | Apr 2025 | AI (unspecified generative tool) | Other | None | May 2026 |
| Dutt v. DGK Roofing and Home, L.L.C. | Ohio Ct. Com. Pl. (Preble Cnty.) Preble County Court of Common Pleas, Civil Division (Ohio) | Mar 2025 | Unidentified in the court's entries (the entry finds "This citation does not exist" and does not mention AI; in a later disciplinary proceeding, counsel's answer admits he used AI to help write the motion and told the judge so in chambers after the damages hearing) | Other | None | Sep 2026 |
| Mi Hui Chon Salyer v. Clinton Salyer | Ky. Ct. App. Kentucky Court of Appeals | Mar 2025 | Unidentified (the court says it issued a show-cause order "suspecting that artificial intelligence was used to obtain case citations that do not exist"; the opinion names no tool and makes no finding that AI was used) | Warning | None | Sep 2026 |
| Kruglyak v. Home Depot U.S.A., Inc. | W.D. Va. U.S. District Court, Western District of Virginia, Abingdon Division | Mar 2025 | ChatGPT and Gemini (Kruglyak acknowledged using free generative-AI tools to conduct legal research) | Warning | None | Oct 2026 |
| Pettit v. Allina Health System | D. Minn. U.S. District Court, District of Minnesota | Mar 2025 | Unidentified (the orders find that a cited state probate decision does not say what counsel represented and do not attribute the error to AI or name a tool; the only mention of AI is the court's quotation of plaintiff's argument that motions to compel are templated "[w]ith the advent of word processing and even [artificial intelligence] and brief banks") | Court sanction | $10,000 under Rule 11, jointly and severally against attorney Richard Hechter and Morris Law Group, P.A., and dismissal of the case with prejudice | Sep 2026 |
| Loyer v. Wayne County, Michigan | E.D. Mich. U.S. District Court, Eastern District of Michigan, Southern Division | Mar 2025 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Stevens v. BJC Health System | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District, Division Three | Mar 2025 | AI (inferred by the court; not acknowledged by the appellant) | Other | None | May 2026 |
| Norman v. Beaumont Independent School District | E.D. Tex. U.S. District Court, Eastern District of Texas, Beaumont Division | Mar 2025 | Generative AI (tool not specified by court; sanctioned attorney completed two AI ethics CLE courses in response to a prior sanction) | Court sanction | $2,000.00 monetary penalty plus mandatory CLE | May 2026 |
| Mark Lillard v. Offit Kurman, P.A. | Del. Super. Ct. Delaware Superior Court, New Castle County | Mar 2025 | Unidentified (the plaintiff acknowledged using generative AI to prepare his filing; no specific tool or platform named) | Other | None | May 2026 |
| Nguyen v. Savage Enterprises | E.D. Ark. U.S. District Court, Eastern District of Arkansas, Central Division | Mar 2025 | Unspecified generative AI | Court sanction | $1,000 | May 2026 |
| Merz v. City of Kalama | W.D. Wash. U.S. District Court, Western District of Washington | Feb 2025 | Unspecified generative AI (referenced on the record by the litigant as 'Artificial Intelligence') | Other | None | May 2026 |
| Wadsworth v. Walmart Inc. | D. Wyo. U.S. District Court, District of Wyoming | Feb 2025 | MX2.law (Morgan & Morgan in-house AI platform) | Court sanction | $5,000 total: $3,000 (Ayala) + $1,000 each (Morgan, Goody); Ayala's pro hac vice revoked | May 2026 |
| Gonzalez v. Texas Taxpayers and Research Association | W.D. Tex. U.S. District Court, Western District of Texas | Jan 2025 | Lexis Nexis AI | Court sanction | $3,961 | May 2026 |
| Brian M. Stolar 1998 Family Trust v. American General Life Insurance Company | D.N.J. U.S. District Court, District of New Jersey | Jan 2025 | No tool at issue; the order's AI paragraph names ChatGPT only as an example ("any AI Tool (e.g., ChatGPT)") of a tool that may not be used with protected material unless it meets the order's conditions | Other | None | Sep 2026 |
| Fora Financial Asset Securitization 2021, LLC v. Teona Ostrov Public Relations, LLC | Sup. Ct. N.Y. Cty. New York Supreme Court, New York County | Jan 2025 | Unidentified (the order says only that citations led "to different or non-existent cases" and that a quotation "did not appear in any cases cited"; it does not mention AI or name a tool) | Warning | None | Sep 2026 |
| Arajuo v. Wedelstadt | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Jan 2025 | Unspecified generative AI (court referenced ChatGPT as example) | Warning | None | Oct 2026 |
| Strike 3 Holdings, LLC v. Doe | C.D. Cal. U.S. District Court, Central District of California | Jan 2025 | Unspecified generative AI | Warning | None | Oct 2026 |
| United States v. Hayes | E.D. Cal. U.S. District Court, Eastern District of California | Jan 2025 | Unspecified generative AI | Court sanction | $1,500 | May 2026 |
| Kohls v. Ellison | D. Minn. U.S. District Court, District of Minnesota | Jan 2025 | AI (via expert declaration from Prof. Jeff Hancock) | Other | None | Sep 2026 |
| Al-Hamim v. Star Hearthstone, LLC | Colo. Ct. App. Colorado Court of Appeals | Dec 2024 | AI (unspecified) | Warning | None | Oct 2026 |
| Gauthier v. Goodyear Tire & Rubber Co. | E.D. Tex. U.S. District Court, Eastern District of Texas | Nov 2024 | Claude | Court sanction | $2,000 | May 2026 |
| Kasten Berry Inc. v. Stewart | D. Kan. U.S. District Court, District of Kansas | Nov 2024 | Unidentified generative AI tool | Court sanction | Counsel agreed to reimburse opposing party's fees; specific dollar amount not fixed in the November 14, 2024 order | Apr 2026 |
| Churchill Funding I LLC v. 732 Indiana, LLC | Cal. Super. Ct. (L.A. Cnty.) Superior Court of California, County of Los Angeles, West District (Santa Monica) | Oct 2024 | Not mentioned in the order | Other | None | Sep 2026 |
| Mortazavi v. Booz Allen Hamilton, Inc. | C.D. Cal. U.S. District Court, Central District of California | Oct 2024 | Unspecified generative AI | Court sanction | $2,500 | Apr 2026 |
| Thomas v. Commissioner of Internal Revenue | T.C. U.S. Tax Court | Oct 2024 | Implied (large language model suspected; counsel denied knowing use, but court found Pretrial Memorandum bore the hallmarks of LLM output) | Court sanction | None (symbolic sanction; Pretrial Memorandum deemed stricken) | Apr 2026 |
| In re Asbury Automotive Group, Inc. | FTC ALJ Federal Trade Commission, Office of Administrative Law Judges | Sep 2024 | Generative AI generally; the order names ChatGPT, Microsoft Copilot, Harvey.AI, and Google Gemini as examples | Other | None | Sep 2026 |
| United States v. Michel | D.D.C. U.S. District Court for the District of Columbia | Aug 2024 | EyeLevel.AI (generative AI) | Other | None | Apr 2026 |
| Rasmussen v. Rasmussen | Cal. Super. Ct. (Sonoma Cnty.) Superior Court of California, County of Sonoma | Aug 2024 | Unspecified generative AI | Court sanction | Not stated | May 2026 |
| Dukuray v. Experian Information Solutions | S.D.N.Y. U.S. District Court, Southern District of New York | Jul 2024 | Unidentified (defendants suggested ChatGPT or similar; plaintiff did not deny) | Court sanction | Not stated | May 2026 |
| Iovino v. Michael Stapleton Associates, Ltd. | W.D. Va. U.S. District Court for the Western District of Virginia, Harrisonburg Division | Jul 2024 | Anthropic Claude 3 Opus (per counsel's sworn declaration); MSA characterized the errors in its opposition brief as 'ChatGPT run amok' | Other | None | May 2026 |
| Leslie v. IQ Data Int'l | N.D. Ga. U.S. District Court, Northern District of Georgia, Atlanta Division | Jun 2024 | Implied (generative AI use inferred from the citation pattern; specific tool not identified on the available record) | Court sanction | None (case dismissed with prejudice as the sanction) | May 2026 |
| Plumbers & Gasfitters Union Local No. 75 Health Fund v. Morris Plumbing, LLC | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Apr 2024 | Unidentified (the court wrote that it "suspects" the citation was "an instance of provision of falsified case authority derived from artificial intelligence"; no tool is named and the order records no explanation from counsel) | Warning | None | Sep 2026 |
| Grant v. City of Long Beach | 9th Cir. U.S. Court of Appeals for the Ninth Circuit | Mar 2024 | Unidentified (the opinion finds two cited cases "do not appear to exist" and many others misrepresented, but does not mention AI or name a tool) | Court sanction | Non-monetary: appellants' opening brief struck in its entirety under Ninth Circuit Rule 28-1 and the appeal dismissed | Oct 2026 |
| United States v. Cohen | S.D.N.Y. U.S. District Court, Southern District of New York | Mar 2024 | Google Bard (specifically named; Cohen described it on the record as 'a super-charged search engine') | Other | None | May 2026 |
| In re Thomas Grant Neusom | M.D. Fla. U.S. District Court, Middle District of Florida | Mar 2024 | Unspecified (attorney admitted he 'may have used artificial intelligence') | Bar discipline | Not stated | May 2026 |
| Morgan v. Community Against Violence | D.N.M. U.S. District Court, District of New Mexico | Feb 2024 | ChatGPT (referenced in opinion footnote discussing legal-ethics implications of AI-authored motions) | Court sanction | Not stated | May 2026 |
| Kruse v. Karlen | Mo. Ct. App. E.D. Missouri Court of Appeals, Eastern District | Feb 2024 | AI (unspecified) | Court sanction | $10,000 | Apr 2026 |
| Smith v. Farwell | Norfolk Sup. Ct. Commonwealth of Massachusetts, Norfolk Superior Court | Feb 2024 | Unidentified generative AI system (the court was unable to identify the specific product used; plaintiff's counsel represented he did not know which AI system his associate had used to prepare the oppositions) | Court sanction | $2,000 payable to the Clerk of Court within 10 days | Apr 2026 |
| Park v. Kim | 2d Cir. U.S. Court of Appeals for the Second Circuit | Jan 2024 | ChatGPT | Court sanction | Not stated | Oct 2026 |
| Matter of Samuel | N.Y. Sur. Ct. New York Surrogate's Court, Kings County | Jan 2024 | Unidentified (the court addressed an allegation that counsel relied on "a website which contained information created by generative artificial intelligence"; it found five of six cited cases erroneous or nonexistent "[e]ven without definitive proof that AI was used," and names no tool) | Court sanction | Reply affirmation struck from the record; counsel directed to appear on January 30, 2024 on whether economic sanctions under 22 NYCRR 130-1.1 are warranted (outcome of that appearance not located) | Sep 2026 |
| People v. Crabill | Colo. OPDJ Colorado Office of the Presiding Disciplinary Judge | Nov 2023 | ChatGPT | Bar discipline | 1 year + 1 day suspension; 90 days active | Apr 2026 |
| In re Celsius Network LLC | Bankr. S.D.N.Y. United States Bankruptcy Court, Southern District of New York | Nov 2023 | Unspecified generative AI | Other | None | May 2026 |
| Thomas v. Pangburn | S.D. Ga. U.S. District Court, Southern District of Georgia, Savannah Division | Oct 2023 | Generative AI inferred from the citation pattern; Plaintiff did not disclose the source. Plaintiff said only that he 'relied on research [he] conducted by [him]self' and 'assumed the citations provided were accurate and reliable' (Doc. 47). | Court sanction | Not stated | May 2026 |
| Frier v. Hingiss | E.D. Wis. U.S. District Court, Eastern District of Wisconsin | Sep 2023 | Unidentified (the court wrote "[t]o the extent the briefing was prepared using 'artificial intelligence,'" counsel remains responsible for it; the order does not find AI was used or name a tool) | Warning | None | Sep 2026 |
| Ex parte Lee | Tex. App.—Waco Court of Appeals of Texas, Tenth District (Waco) | Jul 2023 | Unspecified generative AI | Other | None | May 2026 |
| Mata v. Avianca, Inc. | S.D.N.Y. U.S. District Court, Southern District of New York | Jun 2023 | ChatGPT | Court sanction | $5,000 | May 2026 |
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