Sanctions · A running list

The weight behind the warning — in actual discipline orders.

Hallucinated authorities aren't a future risk. They're a present‑tense list of attorneys disciplined, fined, suspended, and referred — across federal courts, state courts, and bar authorities.

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$2M+
in fines, fee awards, and sanctions already ordered against attorneys for citing authorities that didn't exist.
54 months
of suspensions handed down — attorneys pulled from practice over a filing with a fabricated citation in it.
1,900+
matters on record across federal courts, state courts, and bar authorities — and climbing every week.
§ I — The highest‑profile cases

Sanctions are here now. Suspensions are already in effect.

This isn't fringe. Mata v. Avianca — the case that started it all. A prosecutor in a Georgia murder appeal, suspended. Anthropic's own outside counsel, citing a source Anthropic's own model invented. A six‑figure cost award in an Oregon inheritance fight.

Every case below started as a brief that left an office with a fabricated citation in it — filed by a careful lawyer who didn't think it could happen to them. The only way to stop being on this list is to verify every cite, every time, before the filing leaves the office.

These are just some of the highest‑profile incidents. The full record runs to 1,900+ matters across federal courts, state courts, and bar authorities.

Browse the full database →
Jun 2023

Mata v. Avianca, Inc

Lawyer · 18 fabricated items

Outcome: Monetary Fine (Lawyers & Firm); Letters to Client/Judges · $5,000 USD

S.D. New York
May 2025

Concord v. Anthropic

Expert

Outcome: Part of brief was struck; court took it into account as a matter of expert credibility

N.D. California
Mar 2026

Joel A. Rivera v. Triad Properties Corporation, et al.

Lawyer · 6 fabricated items

Outcome: Public Reprimand; Disqualification; Bar Referral; Publication and Notice of Order; Adverse Costs Order · $35,603 USD

N.D. Alabama
May 2026

Hannah Renee Payne v. The State

Judge, Prosecutor · 4 fabricated items

Outcome: Admonishment; 6-month suspension from appearing before the Supreme Court; 12 hours CLE; trial court order vacated and case remanded; Georgia Supreme Court (S26A0459) admonished ADA Deborah Leslie and the Clayton County DA's Office for failing to verify AI-generated citations in briefs and a proposed order; suspended Leslie's privilege to practice before the Court for six months, reinstatement conditioned on 12 hours of CLE in ethics, brief writing, and proper AI use; vacated the trial court's order and remanded for a new order free of fabricated citations.

SC Georgia
Jun 2026

Lnu v. Blanche

Lawyer · 14 fabricated items

Outcome: Monetary Sanction; 6-month Suspension; Notification Requirement; Bar Suspension · $5,000 USD

9th Cir. CA
May 2026

In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law

Lawyer · 1 fabricated item

Outcome: Monetary Sanction; Bar Suspension; Appellate Division, First Department granted the Attorney Grievance Committee motion for interim suspension of Janelle Melissa Lewis from the practice of law in New York, effective immediately and until further order of the court, under 22 NYCRR 1240.9(a)(1) and (3), after she refused to appear for an examination under oath and failed to comply with Attorney Grievance Committee investigative demands issued during an inquiry into citations to nonexistent cases, attributed to AI hallucination, that she included in a brief drafted for a Texas immigration attorney; ordered to comply with the rules governing suspended attorneys and return any secure pass; may request a post-suspension hearing within 20 days. · $1,500 USD

App. Div. 1st Dept (NY)
Sep 2025

Teniah Tercero v. Sacramento Logistics, LLC, et al.

Lawyer · 7 fabricated items

Outcome: Monetary sanction; Order to be server on client; State Bar notified; State Bar of California concluded the referral against Sepideh Ardestani with a 30-day suspension actually served, alongside probation for one year and 10 hours of technology CLE, effective August 7 2026 · $1,500 USD

E.D. California
Mar 2026

Couvrette v. Wisnovsky

Lawyer · 2 fabricated items

Outcome: Briefs struck; Monetary sanction (15.5k); Adverse costs order (94.7k); claims dismissed with prejudice; Following the Court's Dec. 12, 2025 sanctions order (briefs stricken, Mr. Brigandi ordered to pay a $15,500 monetary sanction, the order permitting Mr. Murphy to leave the case set aside and Mr. Murphy ordered to show cause, claims dismissed with prejudice, and a copy directed to the Oregon State Bar), the Court's March 23, 2026 Opinion and Order set the total fee/cost award at $94,704.38, apportioned 85% to Mr. Brigandi ($80,498.72) and 15% to Mr. Murphy ($14,205.66) for his failure to meaningfully participate as local counsel, and ordered Mr. Murphy to attach a copy of the order to any future local-counsel sponsorship motion in the district. On June 12, 2026, the Court separately ordered Mr. Brigandi to show cause by July 12, 2026 why he should not be held in contempt and further sanctioned for failing to comply with the Court's order; Mr. Brigandi filed a response July 23, 2026, and the docket shows no ruling yet as of the last available entry (Aug 12, 2026). · $110,204 USD

D. Oregon
Aug 2025

ByoPlanet International v. Johansson and Gilstrap

Lawyer · 15 fabricated items

Outcome: Cases dismissed without prejudice, attorney ordered to pay defendants' attorney fees, referred to Florida Bar.; S.D. Fla. (Judge Leibowitz) found Attorney James Martin Paul engaged in repeated, systemic, bad-faith misuse of generative AI across eight related filings, producing hallucinated cases and fabricated quotations; dismissed all four consolidated cases; ordered Paul to pay Defendants Knecht and Novak $36,663.00 and Defendant Gilstrap $48,904.75 (total $85,567.75) in fees and costs within 90 days; required Paul to attach the sanctions order to every future filing in the Southern District of Florida for two years; referred Paul to the Florida Bar for appropriate discipline · $85,567 USD

S.D. Florida
Jun 2026

LiveVideo.AI Corp. v. Redstone

Lawyer · 3 fabricated items

Outcome: Adverse Costs Order; Bar Referral; Court granted Defendants' sanctions motion in full: ordered Plaintiff LiveVideo.AI Corp. and its counsel Alfred Camillo Constants III to pay $85,056 in attorneys' fees and costs under 28 U.S.C. Section 1927 and the court's inherent power, for filing thirteen docket entries of meritless, AI-drafted motions containing hallucinated non-existent quotations and case citations, in violation of a filing injunction and for the purpose of harassing Defendants; Constants was again referred to the SDNY Grievance Committee. · $85,056 USD

S.D. New York
§ II — Fee‑shifting

Your sanction funds your opponent.

Under modern Rule 11(c)(4), when opposing counsel files the sanctions motion, the court is expressly authorised to award them the prevailing party's reasonable attorney's fees and expenses directly resulting from the violation — i.e. the hours billed looking up the cases that don't exist, drafting the show‑cause papers, and arguing the sanctions motion. The same logic runs through the court's inherent power for bad‑faith conduct, 28 U.S.C. § 1927, and Cal. Code Civ. Proc. § 907 for frivolous appeals.

That flips the incentive. Opposing counsel used to read your cites to argue with them — not to verify they existed. Today, every hour they spend pulling your reporter is recoverable if a single citation is fabricated. The bigger the fabrication, the bigger the bill. Every cite in your filing now has a reader with a meter running — and the meter is on your side of the ledger.

Step 1

Opposing counsel flags the cite.

A clerk pulls the reporter. The case isn't there. A letter goes to the filing attorney naming the fabrications.

Notice
Step 2

Filer doubles down — or denies.

"Scrivener's error." "My staff filed the wrong draft." "I was going too fast in my research." In Kjoller, in Shayan, in Torres Campos — the cover story makes it worse.

Cover
Step 3

Court finds bad faith.

Rule 11 reasonableness fails. Inherent power kicks in. Section 1927 if the misconduct multiplied proceedings. The meter starts running on every hour opposing counsel billed because of the fabrication.

Bad faith
Step 4

Fee‑shifting order.

The fine is calculated to the actual fees and costs incurred by opposing counsel. It is paid by the attorney, not the client. The order is forwarded to the state bar. In the UK, the wasted costs order issues directly against the lawyer and is unrecoverable from the client.

Pay
§ III — Don't be the next entry

Verify every cite, every time — before the filing leaves the office.

Verbatim reads the draft brief and produces a report that says, for every authority cited, whether the cite is real and whether the quoted language actually appears in the cited opinion at the pin cite. Same brief, same report, every time — with a link from every verified cite back to the source.