Comparison · Verbatim vs. Lexis & Westlaw

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

For decades, every U.S. law student has learned to research on Lexis and Westlaw. Both are trusted names, and both ship citation‑checking tools that generations of associates rely on. And yet their newer AI assistants have surfaced authorities that don't exist — and courts have sanctioned the lawyers who filed them.

No affiliation. DocPost and Verbatim are not affiliated with, sponsored by, or endorsed by LexisNexis, RELX, Thomson Reuters, Casetext, or any of their affiliates. LexisNexis®, Lexis+®, Protégé®, and Shepard's® are trademarks of RELX Inc. and its affiliates. Westlaw®, KeyCite®, and CoCounsel® are trademarks of Thomson Reuters. All product names are the property of their respective owners and are used here only to identify those products.

What Verbatim is
§ I — On the sanctions record

The incumbents named in the record.

The legal titans haven't kept up with the technology of the times and are getting called out by name with hallucinated citations.

Lexis · LexisNexis, Lexis+ AI, Protégé

11 matters · filter the full database →
Case
Court
Date
Outcome
Penalty
Chakma v. Sushi Katsuei, Inc.
Lawyer · 2 fabricated items
LexisNexis
S.D. New York
United States
May 19, 2026
Monetary Sanction
$2,712 USD
Barber v. Morawa
Lawyer · 2 fabricated items
ClaudeChatGPTWestlawLexisNexis
CA Michigan
United States
May 5, 2026
Admonishment in court
Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al.
Lawyer · 7 fabricated items
LexisNexis
S.D. New York
United States
Apr 29, 2026
Monetary Sanction; Order to Notice Client
$2,500 USD
Tekoma Chaney v. Transdev Services Inc. et al.
Lawyer · 3 fabricated items
LexisNexis
C.D. California
United States
Apr 28, 2026
Monetary Sanction; Reporting to other courts
$2,500 USD
Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC
Lawyer · 1 fabricated item
LexisNexis
S.D. New York
United States
Mar 10, 2026
Public admonition of counsel over AI-hallucinated citations; the court cautioned that future misconduct could warrant discipline. The separate Rule 11 motion was denied.
Lifetime Well LLC v. IBSpot.com Inc.
Lawyer · 3 fabricated items
LexisNexis
E.D. Pennsylvania
United States
Jan 26, 2026
Monetary Sanction; Order to share opinion with Professional Association
$4,000 USD
Viken v. Schuelke
Lawyer · 4 fabricated items
LexisNexis
Minnesotta DC
United States
Jan 13, 2026
Order to Show Cause
Buchanan v. Vuori, Inc.
Lawyer · 2 fabricated items
ChatGPTClaudeClear BriefLexisNexisWestlaw
N.D. California
United States
Nov 20, 2025
Monetary Sanction; Referral to the Bar; Motions stricken without leave to refile; Monetary sanction of $250 payable to the Clerk of Court; attorney James Dal Bon referred to the Northern District of California's Standing Committee on Professional Conduct (which may notify the State Bar of California)
$250 USD
Flowz Digital v. Caroline Dalal
Lawyer · 3 fabricated items
LexisNexis
C.D. California
United States
May 5, 2025
Monetary Sanction; Bar Referral; Court imposed a $3,500 sanction on plaintiff's counsel Omid Khalifeh (paid July 2025) and ordered him to notify the California State Bar of the sanction
$3,500 USD
Gonzalez v. Texas Taxpayers and Research Association
Lawyer · 5 fabricated items
LexisNexis
W.D. Texas
United States
Jan 29, 2025
Plaintiff's response was stricken and monetary sanctions were imposed.
$3,961 USD
Iovino v. Michael Stapleton Associates, Ltd.
Lawyer · 5 fabricated items
ClaudeWestlawLexisNexis
W.D. Virginia
United States
Oct 10, 2024
No sanction, but hearing transcript sent to bar authorities

Westlaw · Westlaw & CoCounsel, Thomson Reuters

12 matters · filter the full database →
Case
Court
Date
Outcome
Penalty
Barber v. Morawa
Lawyer · 2 fabricated items
ClaudeChatGPTWestlawLexisNexis
CA Michigan
United States
May 5, 2026
Admonishment in court
Anthony C. Hill v. Workday, Inc. (2)
Lawyer · 2 fabricated items
Westlaw
N.D. California
United States
Apr 28, 2026
Admonishment; Monetary Fine; 4 hours live CLE; Order Circulation
$1,001 USD
United States v. Farris
Lawyer · 3 fabricated items
Westlaw
6th Cir. CA
United States
Apr 3, 2026
Counsel disqualified with no compensation for time served; Briefs locked; Bar Referral; Notice of Opinion; Referred to the Disciplinary Clerk for the Kentucky Bar Association (and to the Sixth Circuit Chief Judge for disciplinary proceedings under 6th Cir. Local Rule 46)
Heimkes v. Fairhope Motorcoach Resort Condominium Owners Association, Inc.
Lawyer · 3 fabricated items
Westlaw
S.D. Alabama
United States
Mar 31, 2026
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
CVTEK, LLC (B-423943; B-423943.2)
Lawyer · 2 fabricated items
Westlaw
GAO
United States
Feb 12, 2026
Warning
Buchanan v. Vuori, Inc.
Lawyer · 2 fabricated items
ChatGPTClaudeClear BriefLexisNexisWestlaw
N.D. California
United States
Nov 20, 2025
Monetary Sanction; Referral to the Bar; Motions stricken without leave to refile; Monetary sanction of $250 payable to the Clerk of Court; attorney James Dal Bon referred to the Northern District of California's Standing Committee on Professional Conduct (which may notify the State Bar of California)
$250 USD
Pelishek v. City of Sheboygan
Lawyer · 17 fabricated items
Westlaw
E.D. Wisconsin
United States
Sep 18, 2025
Monetary Sanction
$4,500 USD
Anthony C. Hill v. Workday, Inc. (1)
Lawyer · 2 fabricated items
Westlaw
N.D. California
United States
Sep 5, 2025
Order to circulate decision in law firm; CLE
Coomer v. Lindell/MyPillow, Inc. (1)
Lawyer · 8 fabricated items
Microsoft CopilotWestlawGoogle GeminiGrokClaudeChatGPTPerplexity
D. Colorado
United States
Jul 7, 2025
Monetary Sanctions
$6,000 USD
USA v. Burke
Lawyer · 21 fabricated items
WestlawChatGPT
M.D. Florida
United States
May 15, 2025
Motion dismissed, and plaintiff ordered to refile it without fake citations.
Lacey v. State Farm General Insurance
Lawyer · 6 fabricated items
WestlawGoogle Gemini
C.D. California
United States
May 6, 2025
Striking of briefs; denial of requested discovery relief; Large monetary sanctions jointly and severally against the two law firms
$31,100 USD
Iovino v. Michael Stapleton Associates, Ltd.
Lawyer · 5 fabricated items
ClaudeWestlawLexisNexis
W.D. Virginia
United States
Oct 10, 2024
No sanction, but hearing transcript sent to bar authorities
§ II — What's on the line

The tool made up the citation. You're the one who gets sanctioned.

The AI vendor isn't standing next to you at the hearing. When a citation turns out not to exist, it's your signature on the brief, your name in the order, and your standing in front of the court and the bar. Every matter above began with a lawyer who trusted the draft.

Verbatim is how you catch it first. Before the filing leaves your desk, you see which authorities are real and quoted accurately — and which ones you can't stand behind. Draft on Lexis, Westlaw, or anything else; put your name only on citations that hold.

Nothing missed

Nothing slips through.

You never find out at the hearing that the one citation nobody had time to double‑check was the one that was invented.

Complete
Holds up

Stands up when it's challenged.

When opposing counsel or the judge tests a citation, what they find is what you already saw. No surprises on the record.

Defensible
No false comfort

You hear the bad news first.

A citation that can't be confirmed comes back flagged — so you're the one who learns it's weak, not the court.

Honest