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.

Back to Verbatim
$2M+
in fines, fee awards, and sanctions already ordered against attorneys for citing authorities that didn't exist.
38 months
of suspensions handed down — attorneys pulled from practice over a filing with a fabricated citation in it.
1,800+
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 1,800+ 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; Public reprimand of attorney Joshua B. Watkins and law firm Burrill Watkins LLC under Rule 11 and the court's inherent authority; 3-month suspension of Mr. Watkins from practice in the Northern District of Alabama; the Clerk of Court directed to serve a copy of the order on the General Counsel of the Alabama State Bar and any other applicable licensing authorities for further proceedings as appropriate; Watkins and the firm ordered to provide a copy of the order to their clients, opposing counsel, and the presiding judge in every pending state or federal case in which they are counsel of record, and to every attorney in the firm, within ten days, certifying compliance within twenty-four hours; Watkins directed to give the Clerk a list of all jurisdictions in which he is licensed within twenty-four hours; Watkins and the firm disqualified from further participation in the case; order submitted for publication in the Federal Supplement; attorney's fees awarded against counsel: Burrill Watkins to pay the Triad Defendants $11,453, and Watkins and Burrill Watkins jointly and severally to pay the Fite Defendants $35,603.90, a combined $47,056.90. · $47,056.9 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

SC Georgia
Jun 2026

Lnu v. Blanche

Lawyer · 14 fabricated items

Outcome: Monetary Sanction; 6-month Suspension; Notification Requirement; Bar Suspension; Attorneys Mike Singh Sethi and William Rounds each personally sanctioned $2,500 ($5,000 aggregate); each suspended from practice before the Ninth Circuit for six months; ordered to serve the order on their clients, opposing counsel, and the presiding judge in every pending case plus every attorney in their firm within ten days (certify within 24 hours); order served on the State Bar of California; and a generative-AI disclosure/verification statement required in every firm filing for two years. · $5,000 USD

9th Cir. CA
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 · $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.; Attorney James Martin Paul ordered to pay defendants' attorney fees and costs totaling $85,567.75 ($36,663.00 to defendants Knecht and Novak and $48,904.75 to defendant Gilstrap), payable in full within 90 days; cases dismissed; referred to The Florida Bar; ordered to attach the sanctions order to future filings in the district for two years · $85,567.75 USD

S.D. Florida
Jun 2026

LiveVideo.AI Corp. v. Redstone

Lawyer · 3 fabricated items

Outcome: Adverse Costs Order; Bar Referral; Ordered plaintiff LiveVideo.AI Corp and its counsel Alfred Camillo Constants III to pay $85,056 in attorneys' fees and costs to Defendants within 21 days under 28 U.S.C. § 1927 and the court's inherent power; Constants again referred to the Grievance Committee of the United States District Court for the Southern District of New York for such action as it deems appropriate. · $85,056 USD

S.D. New York
Mar 2026

Heimkes v. Fairhope Motorcoach Resort Condominium Owners Association, Inc.

Lawyer · 3 fabricated items

Outcome: Reprimand; Order to file order in subsequent cases; Bar Referral; Adverse Costs Order; Ordered to pay $55,597.00 in defense attorney's fees; referred to the Alabama State Bar · $55,597 USD

S.D. Alabama
May 2026

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

Lawyer · 1 fabricated item

Outcome: Interim suspension from the practice of law in the State of New York, effective immediately and until further order of the court, imposed under 22 NYCRR 1240.9(a)(1) and (3) for failure to appear for an examination under oath and failure to comply with the Attorney Grievance Committee's lawful investigative demands; ordered to comply with the rules governing suspended attorneys (22 NYCRR 1240.15) and to return any secure pass.

App. Div. 1st Dept (NY)
§ 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.