Several lawyers have faced sanctions for failing to verify AI-generated content:
United States v. Farris, 171 F.4th 920 (6th Cir. 2026): Attorney was denied any Criminal Justice Act compensation, removed from the case entirely, and referred for potential disciplinary proceedings for filing briefs containing AI-generated hallucinated quotations and misrepresenting the holdings of two cases.
Seither & Cherry Quad Cities, Inc. v. Oakland Automation, LLC, Case No. 23-11310, Case No. 23-11342, 2025 WL 2105286 (E.D. Mich. Jul. 28, 2025): Attorneys were sanctioned and ordered to pay defense counsel’s costs related to responding to hallucinated citations.
Lacey v. State Farm Case No. CV 24-5205 FMO-MAA, 2025 WL 1363069 (C.D. Cal. May 5, 2025): The court imposed a $31,000 sanction and denied relief to attorneys who filed a brief that contained nine incorrect citations.
Wadsworth v. Walmart, Inc., 348 F.R.D. 489 (D. Wyo. 2025): Three lawyers were sanctioned for filing motions with eight non-existent case citations. One attorney (the drafter) had his pro hac vice status revoked and was fined $3,000; the other two lawyers were each fined $1,000
Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025): Three lawyers—one who used generative AI and two who later reviewed the document—were publicly sanctioned and disqualified from further participation in the case for filing a motion with hallucinated case citations and quotations.
Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023): Attorneys were fined $5,000 for submitting a brief with fabricated citations generated by ChatGPT.
For a comprehensive list of court decisions referencing the use of hallucinated caselaw and quotes, please see the AI Hallucination Database (linked with permission from the author).
Lawyers may also face sanctions for billing clients for work product generated by AI. See, e.g.:
In re: Burghoff, 374 B.R. 681 (Bankr. N.D. Iowa, 2007): Attorney violated the Iowa Rules of Professional Conduct by charging his client for work largely plagiarized from an article written by other attorneys.