AI sanctions tracker

Courts are sanctioning lawyers for AI-fabricated citations. Here is the record.

1,598

Court cases involving AI-hallucinated citations or content documented in the public AI Hallucination Cases database as of June 9, 2026 — up from roughly 200 a year earlier, with new incidents added nearly every day.

source: AI Hallucination Cases database (damiencharlotin.com) · growth reporting: ABA Journal

last reviewed by Lavir: July 17, 2026 · figures change as the database grows — follow the source link for today's count

Notable cases

How it actually goes for the lawyer.

A non-exhaustive selection of documented decisions, described conservatively. Full dockets and hundreds more incidents are catalogued in the public database.

Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)

The case that started it: a brief citing multiple nonexistent decisions generated by ChatGPT, defended after opposing counsel couldn't find them.

outcome: $5,000 sanction · national coverage that followed the attorneys' names

Park v. Kim, 91 F.4th 610 (2d Cir. 2024)

A reply brief cited a fake case produced by ChatGPT; the court of appeals addressed counsel's AI use directly.

outcome: referral to the circuit's attorney grievance panel

Gauthier v. Goodyear Tire & Rubber Co. (E.D. Tex. 2024)

Response briefing included nonexistent cases and fabricated quotations attributed to real ones.

outcome: monetary sanction · mandatory continuing legal education on generative AI

Wadsworth v. Walmart Inc. (D. Wyo. 2025)

Motions in limine cited cases that did not exist, produced by a firm's internal AI tool — showing the risk isn't limited to public chatbots.

outcome: monetary sanctions · one attorney's pro hac vice admission revoked

Johnson v. Dunn (N.D. Ala. 2025)

Filings by large-firm defense counsel contained AI-fabricated citations.

outcome: public reprimand · disqualification from the case · bar referrals

Noland v. Land of the Free, L.P. (Cal. Ct. App. 2025)

A published appellate opinion found the overwhelming majority of quotations in the briefs were fabricated — and warned the bar directly.

outcome: $10,000 sanction · published opinion naming the conduct

Case descriptions summarize public decisions and coverage; consult the linked database and the underlying dockets for full detail. Professional-conduct guidance: New York State Bar Association.

The pattern

It's never the AI that gets sanctioned.

Every consequence above landed on the human who signed the filing: fines, fee awards, mandatory education, revoked admissions, bar referrals, published opinions carrying the lawyer's name. Courts have been consistent on the principle — using AI is not the violation; filing unverified AI output is.

The fix is procedural, not technological: verify every citation, quotation, and holding against primary sources before filing — and keep a record showing you did.

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Verify before you file.

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