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
§ I — The list

Sanctions are here now. Suspensions are already in effect.

This isn't fringe. A prosecutor in a Georgia murder appeal. Sullivan & Cromwell — AmLaw 5, 150‑year pedigree — apologising to a federal judge. Anthropic's own outside counsel, citing a journal article Anthropic's own model invented.

Every entry 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.

May 2026

In the Matter of Janelle Melissa Lewis — freelance drafter retained by a Texas immigration attorney to draft a response to an OSC in D.N.M.; brief replete with citations to nonexistent cases attributed to ChatGPT or similar AI; respondent then refused to appear for examination under oath, emailed the AGC calling the investigation "a racist attack," and purported to "resign" by email without filing the required application

App. Div., 1st Dept., New York · per curiam

Discipline: Immediate interim suspension from the practice of law (grounded in non‑cooperation with the EUO and subpoena, not the underlying AI hallucinations); hiring Texas attorney separately fined $1,500 and ordered to self‑report respondent to NY disciplinary authorities

Source · Matter of Lewis, 2026 NY Slip Op 03074 (1st Dept. May 14, 2026)

New York
May 2026

Gregoire v. BART — Jessica Barsotti (BART officer’s counsel)

N.D. Cal. · Magistrate Judge Thomas Hixson

Discipline: $1,000 personal fine + 1 hour CLE on the ethical use of AI in law practice

Source · SF Chronicle · 18 May 2026

California
May 2026

Coomer v. Lindell, No. 1:22‑cv‑01129‑NYW‑SBP — opposition riddled with hallucinated cites; lead counsel admitted using AI and delegating cite‑checks to co‑counsel

D. Colo. · U.S. District Judge Nina Y. Wang

Discipline: $6,000 joint Rule 11 monetary sanction split equally between the lead handling attorney and the co‑counsel’s firm

Source · Order — Coomer v. Lindell, ECF No. 424 (D. Colo. May 7, 2026)

Colorado
May 2026

In re Deborah Leslie (Clayton Cnty. asst. DA) — fictitious cites in proposed order in State v. Payne

Georgia Supreme Court · opinion by Justice Benjamin Land

Discipline: Six‑month suspension from appearing before the Georgia Supreme Court + ordered to complete additional CLE on ethics, brief writing, and proper AI use; the underlying order denying the murder defendant’s new‑trial motion was vacated and remanded

Source · Reuters · 5 May 2026 (Mike Scarcella)

Georgia
Apr 2026

Sullivan & Cromwell — apology to a federal judge over AI hallucination

Federal court (specific docket not detailed in source)

Discipline: Public apology from one of the country’s oldest and most elite firms; illustrative that the failure mode reaches AmLaw 5

Source · Business Insider · 30 Apr 2026 (Melia Russell)

Federal
Apr 2026

In re Omid Emile Khalifeh — notice of disciplinary charges

California State Bar · Office of Chief Trial Counsel

Discipline: Six counts of alleged misconduct (Apr 2025 federal trademark filing)

Source · Hoodline · 14 Apr 2026

California
Apr 2026

In re Steven Thomas Romeyn — notice of disciplinary charges

California State Bar · Office of Chief Trial Counsel

Discipline: Acknowledged not independently confirming cites (Oct 2025 Orange Cnty. brief)

Source · Hoodline · 14 Apr 2026

California
Apr 2026

In re Sepideh Ardestani — disciplinary stipulation approved

California State Bar Court

Discipline: One year probation, 30‑day suspension, 10 hours of CLE on technology (recommendation to Cal. Supreme Court)

Source · Hoodline · 14 Apr 2026

California
Apr 2026

Ross LeBlanc — Dudley DeBosier (real cite, fabricated quotations; AI tool “Eve”)

19th Judicial District Court · Baton Rouge, LA · Judge William Jorden (private letter dated Mar 27, 2026); a separate Lowe’s trip‑and‑fall matter at the firm involving Claude‑assisted drafting is pending a sanctions inquiry

Discipline: Apology letter to the court; sanctions inquiry pending in the related Lowe’s matter

Source · Business Insider · 30 Apr 2026 (Melia Russell)

Louisiana
Mar 2026

Joel A. Rivera v. Triad USA, No. 2:25‑cv‑00123‑MIP — defense filings with AI‑generated false citations; opposing counsel couldn’t locate the authorities

N.D. Ala., Southern Division

Discipline: Rule 11 + disciplinary show‑cause proceedings opened; court addressing bad‑faith conduct that forced the plaintiff to incur additional costs and legal expenses

Source · Order — Rivera v. Triad USA (N.D. Ala. Mar. 31, 2026)

Alabama
Mar 2026

Sheerer v. Panas, 2026 Cal. App. LEXIS 170

Cal. Ct. App., 1st Dist., Div. 4 · Judge Ann C. Moorman

Discipline: Monetary sanctions declined; court underscored every cite must be personally read and verified — GenAI or otherwise

Source · Ropes & Gray AI court order tracker

California
Mar 2026

In re Domestic P’ship of Torres Campos & Munoz, 2026 Cal. App. LEXIS 130

Cal. Ct. App. · C.D. Cal. — Judge Fred W. Slaughter

Discipline: $5,000 sanction on respondent’s counsel + ordered to report sanction to the State Bar

Source · Ropes & Gray AI court order tracker

California
Feb 2026

Veramancini v. Cnty. of Orange, 2026 U.S. Dist. LEXIS 35478

C.D. Cal. · Judge Fred W. Slaughter

Discipline: $2,000 personal Rule 11 sanction + order served on the State Bar of California

Source · Ropes & Gray AI court order tracker

California
Jan 2026

Kjoller v. Superior Court of Nevada County

California Supreme Court (directing OSC to Court of Appeal)

Discipline: Unanimous order directing Court of Appeal to issue OSC re sanctions against the Nevada County DA; civil referee inquiry green‑lit

Source · Jenner & Block client alert · 10 Feb 2026

California
Jan 2026

Hang Zhang v. Driscoll, 2026 U.S. Dist. LEXIS 8654

N.D. Cal. · Judge Araceli Martínez‑Olguín

Discipline: $500 Rule 11 sanction on pro se plaintiff; warning of case‑terminating sanctions on recurrence

Source · Ropes & Gray AI court order tracker

California
Dec 2025

Outreach v. Medoff, 2025 Cal. App. Unpub. LEXIS 8133

Cal. Ct. App., 2d Dist., Div. 4 · Judge Tamzarian

Discipline: $5,070 monetary sanction payable to opposing counsel + opinion forwarded to State Bar; reply brief struck

Source · Ropes & Gray AI court order tracker

California
Dec 2025

Howell Mgmt. Servs., LLC v. Vashisht‑Rota, 2025 Cal. App. Unpub. LEXIS 8006

Cal. Ct. App., 4th Dist. · Judge Joan Irion

Discipline: $59,235 in attorney’s fees + $15,000 to the clerk of court (pro se appellant; frivolous appeal + nonexistent authorities)

Source · Ropes & Gray AI court order tracker

California
Dec 2025

N.Z. v. Fenix Int’l Ltd., 2025 U.S. Dist. LEXIS 259988

C.D. Cal. · Judge Fred W. Slaughter

Discipline: $10,000 sanction on individual attorney + firm (j&s); $3,000 sanction on co‑counsel; orders served on California and Arizona state bars

Source · Ropes & Gray AI court order tracker

California
Dec 2025

Shayan v. Shakib, 2025 LEXIS 595242

Cal. Ct. App., 2d Dist. · Judge William F. Fahey

Discipline: $7,500 sanction payable to clerk of court + opening brief struck + order served on the State Bar

Source · Ropes & Gray AI court order tracker

California
Nov 2025

Anaya v. Target Corp., No. 2:25‑cv‑09135‑SB‑RAO

C.D. Cal. · Judge Stanley Blumenfeld, Jr.

Discipline: $1,250 monetary sanction + notice to the State Bar of California (managing partner separately admonished)

Source · Ropes & Gray AI court order tracker

California
Sep 2025

Sylvia Nola — appellate opening and reply briefs with nearly every primary quote and authority fabricated by GenAI; counsel admitted he never read the opinions the AI cited

Cal. Ct. App., 2d Dist., Div. 3 (Certified for Publication)

Discipline: Direct monetary sanctions on counsel + state bar referral; tied to opposing party’s wasted fees under Cal. Code Civ. Proc. § 907

Source · Cal. Ct. App. 2d Dist. Div. 3 · No. B331918 (Certified for Publication)

California
May 2025

Lacey v. State Farm Gen. Ins. Co., 2025 U.S. Dist. LEXIS 90370

C.D. Cal. → JAMS · Special Master Rule 11 finding (CoCounsel + Westlaw Precision + Google Gemini used to draft; 9 of 27 cites wrong, 2 nonexistent; “collective debacle,” “tantamount to bad faith”)

Discipline: $26,100 to defendant for JAMS fees + $5,000 for defense costs (~$31K total); supplemental briefs disregarded; relief denied

Source · CEB · “A California Law Firm Just Paid $31K in Sanctions” (Jul 2025) · cross‑ref Ropes & Gray tracker

California
May 2025

Concord Music Group, Inc. v. Anthropic PBC, 2025 WL 1482734

N.D. Cal. · Magistrate Judge Susan Van Keulen (expert declaration contained a Claude‑generated hallucinated citation; lead counsel failed to catch it despite a manual review)

Discipline: Expert declaration struck in part; court called the issue “very serious and grave” and found it violated the district judge’s standing order requiring lead counsel to personally verify all filings

Source · Ropes & Gray AI court order tracker · cross‑ref CEB

California
Apr 2025

Ayinde v LB Haringey — barrister used a public‑facing AI tool to draft applications and bundles without independent verification

UK High Court · Mr Justice Ritchie (3 April 2025)

Discipline: Wasted costs order under Senior Courts Act 1981 § 51(6): advocates personally liable for opposing party’s wasted costs — bypassing the client entirely

Source · Judgment — Ayinde v LB Haringey, Ritchie J · 3 Apr 2025

United Kingdom
Jan 2025

United States v. Hayes

E.D. Cal.

Discipline: Monetary sanction + sanction notice sent to every state bar where the attorney is licensed and to every judge in the district

Source · Jenner & Block client alert · 10 Feb 2026

California
Nov 2023

People v. Zachariah C. Crabill

Colorado · Office of Attorney Regulation Counsel

Discipline: A year‑and‑a‑day suspension (ninety days to serve, the remainder stayed on probation) — the first published US discipline of its kind.

Source · Colorado OARC · public discipline order

Colorado
Jun 2023

Mata v. Avianca, Inc.

S.D.N.Y. · Judge P. Kevin Castel

Discipline: $5,000 joint sanction against the attorneys and the firm + referral to bar disciplinary authorities

Source · No. 22‑cv‑1461 (S.D.N.Y. June 22, 2023) · Opinion & Order

New York
§ 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.