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.
60 months
of suspensions handed down — attorneys pulled from practice over a filing with a fabricated citation in it.
2,000+
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 2,000+ 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; S.D.N.Y. (Judge P. Kevin Castel) sanctioned attorneys Steven Schwartz, Peter LoDuca, and their firm Levidow, Levidow & Oberman under Rule 11/inherent authority for submitting a brief citing six fabricated ChatGPT-generated case opinions and doubling down after being challenged; imposed a $5,000 joint-and-several penalty payable to the Court, plus a requirement to send notification letters to the client and to each judge falsely named as an author of a fake opinion; court did not refer the attorneys to disciplinary authorities · $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; Magistrate Judge struck paragraph 9 of Anthropic expert Olivia Chen's declaration after Anthropic's counsel admitted Claude.ai was used to format at least three citations and generated a fictitious article title/authors for one of them; court noted this undermined the declaration's overall 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; N.D. Ala. found Watkins misused generative AI to make false and fabricated statements of law, then repeatedly lied to and misled the court about it, including misrepresenting his communications with his own clients. The court publicly reprimanded Watkins and his former firm Burrill Watkins LLC, disqualified them from the case, ordered the reprimand order served on clients/opposing counsel/presiding judges in every pending matter and published in the Federal Supplement, directed the Clerk to serve the order on the General Counsel of the Alabama State Bar and other applicable licensing authorities, and awarded $11,453 and $35,603.90 in attorney's fees to the defendants. · $47,056.9 USD

N.D. Alabama
Sep 2025

Noland v. Land

Lawyer · 5 fabricated items

Outcome: Monetary Sanction; State Bar notified; opinion to be served on client.; California Court of Appeal (Div. Three) imposed a $10,000 sanction on Attorney Amir Mostafavi for fabricated AI-generated citations and quotes, ordered him to serve the opinion on his client, and directed the clerk to forward the opinion to the State Bar; State Bar Court Judge Yvette D. Roland's stipulated recommendation of a one-year stayed suspension, one-year probation, and 10 hours of AI/tech CLE became effective discipline on 2026-06-26 per the State Bar's public attorney profile · $10,000 USD

CA California
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; Ninth Circuit disciplinary order following an Order to Show Cause: Sethi and Rounds each personally sanctioned $2,500 for filing briefs with hallucinated citations and then denying/obscuring AI use; both suspended from practice before the court for six months starting ten days after the order; ordered to serve copies of the order on clients, opposing counsel, presiding judges in every pending case, and all firm attorneys within 10 days, certifying compliance within 24 hours; required to include an AI-use/verification certification in all filings for two years; Clerk directed to serve the order on the State Bar of California and other applicable licensing authorities · $5,000 USD

9th Cir. CA
Jan 2026

Osborne Properties Limited Partnership v. Fartun Abdullahi Mohamed et al.

Lawyer · 5 fabricated items

Outcome: Citations Struck; Monetary Sanctions; Bar Referral; Court struck the fake/false citations, corrected inaccurate ones, and fined Attorney Faisal S. Ahmed $5,000 under Minn. R. Civ. P. 11.03 and Minn. Stat. Sec. 549.211; referred him to the Minnesota Office of Lawyers Professional Responsibility, which petitioned the MN Supreme Court for a stipulated 30-day suspension plus $900 costs (Aug. 21, 2026) · $5,000 USD

DC Minnesotta
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's motion for interim suspension of Janelle Melissa Lewis, 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 AGC investigative demands issued during an inquiry into citations to nonexistent, AI-hallucinated cases 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)
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; Referred to the Oregon State Bar (Brigandi); on June 12, 2026 the Court separately ordered 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 sanctions order; Brigandi responded July 23, 2026 with no ruling found as of this check · $110,204.38 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 without prejudice; ordered Paul to pay Defendants Knecht and Novak $36,663.00 and Defendant Gilstrap $48,904.75 (total $85,567.75) within 90 days; required Paul to attach the sanctions order to every future S.D. Fla. filing for two years; referred Paul to the Florida Bar for appropriate discipline · $85,567.75 USD

S.D. Florida
§ 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.