You learned Lexis and Westlaw in law school. So did the lawyers on the sanctions list.

Monetary Sanction; Court ordered Defense Counsel personally to pay $1,710 in Class Counsel's attorneys' fees and imposed a separate $1,000 monetary penalty for submitting AI-hallucinated case citations and false authority; Defendants separately ordered to pay $46,980 in fees and $781.88 in costs for related discovery and class-notice misconduct

Admonishment in court; Michigan Court of Appeals (published opinion, No. 374773) held that plaintiff's counsel's repeated submission of fabricated and unsupported AI-generated legal authority in the trial court and on appeal violated MCR 7.216(C)(1)(b) and MCR 1.109(E)(5)-(6); remanded to the trial court to determine defendant's actual damages and attorney fees incurred because of the appeal, payable by counsel personally; and directed the Clerk to forward the opinion to the Attorney Grievance Commission for possible investigation

Monetary Sanction; Order to Notice Client; Rule 11 sanction of $2,500 against plaintiff's counsel; ordered to notify her client and to alert the presiding judge in each of her other pending cases of this Opinion and Order via a filed letter served on opposing counsel; ordered to file a sworn statement describing her compliance

Monetary Sanction; Reporting to other courts; Sanctioned counsel Gavril T. Gabriel $2,500 for bad-faith use of a fabricated case (In re Shubert) cited three times across two summary-judgment oppositions; ordered to file, by May 12, 2026, a declaration disclosing the AI misuse and the court's bad-faith findings in every pending Central District of California case in which he appears, and to email it to judges before whom he was not currently appearing

Publicly admonished for filing hallucinated citations and for misrepresenting the research tool used; warned that further misconduct may lead to sanctions or referral for discipline

Monetary Sanction; Order to share opinion with Professional Association; Court imposed a $4,000 monetary sanction on New York co-counsel Attorney Yen-Yi Anderson, payable to the City Bar Justice Center's Neighborhood Entrepreneur Law Project from her personal funds, plus non-monetary sanctions requiring Attorney Anderson and local counsel Attorney Jeffrey Goldin to each send a cover letter enclosing the Order, Memorandum, and their firm's AI policy to a professional association for member distribution, and requiring Anderson to notify the judges and counsel in two other matters where her law clerk used undisclosed AI. Attorney Goldin voluntarily completed continuing legal education on the ethical use of generative AI and apologized to the Court.

Order to Show Cause

Monetary Sanction; Referral to the Bar; Motions stricken without leave to refile

Monetary Sanction; Bar Referral; Court sanctioned attorney Omid Khalifeh $3,500 under Rules 11 and 16(f) for citing a fabricated case (Shell Petroleum N.V. v. Republic of Costa Rica) and violating the court's AI-disclosure standing order; counsel was also ordered to notify the California State Bar of the sanction. The State Bar's Office of Chief Trial Counsel has since filed a Notice of Disciplinary Charges against Khalifeh (six counts, filed April 1, 2026) arising from this same conduct; the State Bar Court had not yet ruled as of the charges being filed.

Plaintiff's response was stricken and monetary sanctions were imposed.; Attorney John L. Pittman III personally ordered to pay opposing counsel's (TTRA's) attorney's fees of $3,852.50 and costs of $108.54 (total $3,961.04) by February 13, 2025, after citing fabricated and misrepresented case law generated via a LexisNexis AI citation tool -- including three cases that do not exist; Plaintiff's response to the motion to dismiss was stricken.

No sanction, but hearing transcript sent to bar authorities; Court directed that its order and the show-cause hearing transcript be transmitted to the Oregon State Bar and the Virginia State Bar; lead counsel self-reported to the Oregon State Bar, and the Virginia State Bar opened its own investigation and referred the matter to a district committee

CLE on generative AI; Civil Contempt; Adverse Costs Order

Admonishment in court; Michigan Court of Appeals (published opinion, No. 374773) held that plaintiff's counsel's repeated submission of fabricated and unsupported AI-generated legal authority in the trial court and on appeal violated MCR 7.216(C)(1)(b) and MCR 1.109(E)(5)-(6); remanded to the trial court to determine defendant's actual damages and attorney fees incurred because of the appeal, payable by counsel personally; and directed the Clerk to forward the opinion to the Attorney Grievance Commission for possible investigation

Admonishment; Monetary Fine; 4 hours live CLE; Order Circulation; Admonished and personally sanctioned Attorney Lenden Webb $1,001 for failing to supervise a discovery brief containing a fabricated case citation; ordered to circulate this order and the prior show-cause record to all attorneys and paralegals at his firm, and to complete 4 hours of live CLE (supervision and AI ethics) within six months with proof of compliance filed with the court

Counsel disqualified with no compensation for time served; Briefs locked; Bar Referral; Notice of Opinion; Denied Steven N. Howe compensation under the Criminal Justice Act for his appellate work after he filed briefs containing AI-fabricated quotations and misrepresented case holdings; removed him as counsel of record, locked his briefs, and reset the briefing schedule for replacement counsel; referred the matter to the Chief Judge of the Sixth Circuit for discipline under 6th Cir. Local Rule 46 and served a copy on the Disciplinary Clerk for the Kentucky Bar Association

Reprimand; Order to file order in subsequent cases; Bar Referral; Adverse Costs Order; Reprimanded Attorney Franklin Hollis Eaton, Jr. under Rule 11, Alabama Rule of Professional Conduct 3.3, and the court's inherent authority for filing pleadings with fabricated citations and false statements of law; the reprimand must be published (filed in his pending matters and in every matter he appears in for 12 months, and sent to every jurisdiction where he is licensed) and the order was also submitted for publication in the Federal Supplement; ordered to pay $55,597.00 in defense attorneys fees; referred to the General Counsel of the Alabama State Bar with the court's recommendation that he be found incompetent to practice law, and separately referred to the Judges of the Southern District of Alabama under GenLR 83.4(a) and (h)(1) for review

Warning; GAO found the protester's supplemental filing relied on erroneous citations generated by Westlaw's AI tool CoCounsel; GAO declined to impose sanctions but cautioned the protester that any future filing with citations to non-existent authority may result in sanctions being imposed. Counsel apologized and adopted new citation-verification protocols.

Monetary Sanction; Referral to the Bar; Motions stricken without leave to refile

Monetary Sanction; Sept. 18, 2025 order (Magistrate Judge Duffin) resolving the July 23, 2025 show-cause order: $4,000 Rule 11(c) sanction against attorney Jennifer DeMaster and $500 against attorney Chris Kachouroff (joint and several with his firm), both due to the Clerk of Court within 28 days; the court declined to dismiss the action.

Order to circulate decision in law firm; CLE; Sept. 5, 2025 order (N.D. Cal., Magistrate Judge Kang) ruling on the response to the court's earlier show-cause order: publicly admonished Attorney Katherine Cervantes for violating the court's AI Standing Order and Rule 11(b), ordering her to circulate the order/OSC/her response firmwide and complete four hours of live CLE (supervision, ethics, and AI-specific) within six months, with final discharge of the show-cause order as to her deferred until those certifications are reviewed. The court also admonished Attorney Lenden Webb for failing to appear at the hearing, ordered him to file a further declaration within 14 days, and expressly declined to discharge the Order to Show Cause as to him, indicating further action would follow.

Monetary Sanctions; Rule 11 sanctions of $3,000 against Christopher I. Kachouroff and McSweeney Cynkar & Kachouroff PLLC, jointly and severally, and $3,000 against Jennifer T. DeMaster individually, payable to the court registry by August 4, 2025

Defendant's second motion to dismiss the indictment (Doc. 119) was STRICKEN for containing significant misrepresentations and misquotations of case law; refiling was permitted by May 19, 2025 only if accompanied by a separate brief explaining how the misrepresentations occurred and what counsel will do to prevent similarly unacceptable filings

Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms; Special Master struck Plaintiff's supplemental briefs on the disputed privilege issue and denied further discovery relief on it; Ellis George LLP and K&L Gates LLP ordered, jointly and severally, to pay compensation to the defense in the aggregate amount of $31,100

No sanction, but hearing transcript sent to bar authorities; Court directed that its order and the show-cause hearing transcript be transmitted to the Oregon State Bar and the Virginia State Bar; lead counsel self-reported to the Oregon State Bar, and the Virginia State Bar opened its own investigation and referred the matter to a district committee