TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor
Connecticut Supreme Court · Conn. Sup. Ct. · Connecticut bar guidance
Conduct
Lawyer ran verified drafts through ChatGPT to polish the prose; it silently added and altered about seven citations that no one re-checked.
Consequence
Six extra CLE hours, $1,000 each from the lawyer and firm to the CT Bar Institute, six-month compliance report; expressly not a grievance referral.
Lesson
Verification has to happen after the last AI pass, not before it: an editing step can introduce citations the earlier cite-check never saw.
Verified September 28, 2026
- Citation
- TOV Realty, LLC v. Suarez, SC 21183, and Kosel Equity, LLC v. MacGregor, SC 21184 (Conn. July 31, 2026) (per curiam) (order on sanctions)
- Decided
- July 31, 2026
Summary
Attorney Ian G. Gottlieb of GLG Law, LLC filed applications to bring public interest appeals under General Statutes section 52-265a, and briefs, in two appeals. He researched and drafted with LexisNexis and verified the citations in his rough drafts with Shepard's, then "copied and pasted those drafts into ChatGPT, a generative AI program, to make his brief writing process more efficient and to improve the quality of the final written product." Unknown to him, ChatGPT "added new case citations or altered existing case citations." Because the changes did not alter the substance of the legal propositions, neither he nor the firm colleagues who reviewed the documents re-verified the citations. Amici represented by the Jerome N. Frank Legal Services Organization identified the errors. Gottlieb admitted that filing documents with approximately seven erroneous and unverified citations produced by generative AI violated, at a minimum, rule 1.1 of the Rules of Professional Conduct.
- AI tool:
- ChatGPT (admitted; used to edit briefs drafted from LexisNexis research)
- Sanction amount:
- $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
What sanction did the court impose?
Acting under its inherent powers and applying ABA Standards for Imposing Lawyer Sanctions 9.22 and 9.32, the Court found no intent to deceive and ordered: six hours of CLE in ethics and law office management beyond the annual twelve-hour requirement, three of them on generative AI; a $1,000 donation each from Gottlieb and GLG Law, LLC to the CT Bar Institute, Inc.; a compliance report within six months filed with the Court, with a courtesy copy to the Statewide Grievance Committee; and compliance with any reciprocal discipline obligations elsewhere. The order is posted on the Judicial Branch website, and the Court stated that the courtesy copy to the Statewide Grievance Committee "is not a referral for further disciplinary action."
Why does TOV Realty, LLC v. Suarez; Kosel Equity, LLC v. MacGregor matter for law firms using AI?
The Court opened by noting that it was “required to confront for the first time a lawyer’s use of generative artificial intelligence (generative AI) that has resulted in the submission of written materials to this court containing citations that were ‘hallucinated.’” The failure mode it describes arose after careful research. Gottlieb did the research in LexisNexis and Shepardized his rough drafts. The hallucinations entered afterward, when he pasted the verified drafts into ChatGPT to improve the prose. Because the AI-generated changes “did not affect the substantive accuracy of the legal propositions,” nobody at the firm thought to check the citations a second time.
The sanction is calibrated to negligence rather than deceit. The Court found “no intention to deceive” and that “the hallucinated citations resulted from negligence in the use of new technology, rather than an intentional attempt to deceive or mislead this court or other parties,” credited Gottlieb’s candor, cooperation, and lack of disciplinary history, and imposed education and a charitable payment. It also found that the firm shares responsibility, noting that other partners had reviewed the documents before filing and that the firm had no generative AI policy at the time.
The order also serves as a pointer to Connecticut’s new filing rules, including Practice Book section 4-9. The Connecticut tracker page covers those rules and the state’s bar guidance. Firms documenting compliance may wish to consider a final citation check as the last step before filing, after any AI-assisted drafting or editing.
Implications for your firm
Operational steps a firm reading this case may wish to consider documenting. Strategic and rule-application calls belong to your firm's attorneys.
- Verify citations after every AI-assisted editing pass, not only after research. The errors here were introduced when counsel ran already-verified drafts through ChatGPT to improve the writing.
- Document a firm AI policy. The Court found the firm 'shares responsibility given its failure at the time to have policies and procedures in place to address the responsible use of generative AI,' and sanctioned the firm alongside the lawyer.
- Review confidentiality before pasting client work into a public AI platform. The Court noted that the duty of competence includes the implications of generative AI for privilege, confidentiality, and work product, 'particularly when a public access platform is involved.'
- Train on Connecticut's new rules: the order cites Practice Book sections 4-9 (b) and 4-2 (b), effective June 23, 2026, and sections 62-6 (d) and 85-2 (11), effective July 14, 2026.