In June 2023 a federal judge in New York fined two lawyers and their firm $5,000 for a brief that cited six decisions ChatGPT had invented. It was treated as a curiosity. Three years later it is routine. The AI Hallucination Cases database kept by Damien Charlotin listed 2,095 decisions worldwide on 28 September 2026, 1,431 of them in the United States, where a court found a party had relied on fabricated or misrepresented authority.
This page is narrower. It lists orders that did something to the lawyer, a fine, a referral, a reprimand, a suspension, and that we could check against the order itself. Every row links to it.
What the courts are ordering
Read together, the orders escalate in a clear direction.
- Fines have gone from token to real. $5,000 in 2023. Most of the fines in the table fall between $2,000 and $6,000. An Oregon court ordered $15,500 against one lawyer on top of the other side’s fees, which ABA Journal reported brought the total to about $110,000.
- The client hears about it. Almost every order requires the lawyer to send the order to the client. Several require it to go to every judge presiding over the lawyer’s other cases, and to every lawyer at the firm.
- The bar hears about it. Referrals to the state bar or a court’s grievance panel appear from the Second Circuit’s order in January 2024 onward.
- The case can be lost. In Oregon the court struck the briefs and dismissed the plaintiffs’ claims with prejudice. In Alabama three lawyers were removed from the case.
- The right to practice before the court can go. In June 2026 the Ninth Circuit suspended two lawyers from practice before it for six months, and ordered every future filing by their firm for two years to state, under penalty of perjury, whether generative AI was used.
- The tool does not matter. The orders name ChatGPT, Claude, Gemini, Grok, a firm’s in-house platform and legal research products. Several say no tool at all. The sanction attaches to the signature, not the software.
Texas
Four of the orders below come from Texas courts or Texas cases: a $2,000 fine and generative-AI CLE in Beaumont (E.D. Tex., November 2024), $2,500 and three hours of CLE in Laredo (S.D. Tex., July 2025), a $2,000 fee award and a struck motion in a Travis County district court (October 2025), and a $2,500 sanction from the Fifth Circuit on an appeal from the Southern District of Texas (February 2026). The Fifth Circuit’s opinion cites both of the district court orders.
The orders
| Date | Case and court | What was filed | What the court ordered | Order |
|---|---|---|---|---|
| 22 Jun 2023 | Mata v. Avianca, Inc., S.D.N.Y. | An affirmation citing six decisions that did not exist, generated by ChatGPT; counsel then filed copies of the invented opinions | $5,000 against two lawyers and their firm, jointly; letters to the client and to each real judge named as the author of a fake opinion | Opinion |
| 30 Jan 2024 | Park v. Kim, 2d Cir. | A reply brief citing a state appellate decision that does not exist, generated by ChatGPT | Referral to the court’s Grievance Panel; a copy of the ruling to the client, translated if needed | Opinion |
| 25 Nov 2024 | Gauthier v. Goodyear Tire & Rubber Co., E.D. Tex. | A summary judgment response citing two nonexistent Fifth Circuit cases and quotations that do not appear in seven others; the lawyer said he used Claude | $2,000 penalty; a CLE course on generative AI; a copy to the client | Order |
| 24 Feb 2025 | Wadsworth v. Walmart Inc., D. Wyo. | Motions in limine in which eight of nine cited cases did not exist, drafted with the firm’s in-house AI platform | Drafting lawyer’s admission to the case revoked and $3,000 fine; $1,000 each for the supervising and local lawyers | Order |
| 6 May 2025 | Lacey v. State Farm General Ins. Co., C.D. Cal. (special master) | A supplemental brief in which about nine of 27 citations were wrong, at least two to authorities that do not exist, drafted with several AI research tools | Two firms jointly liable for $31,100 in fees; the briefs struck and the relief denied | Report (order not opened; per ABA Journal and a law-firm analysis) |
| 28 May 2025 | Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC, S.D. Ind. | Briefs citing nonexistent cases on three occasions | $6,000 against the lawyer personally (the magistrate judge had recommended $15,000); a separate referral to the state disciplinary commission | Order |
| 7 Jul 2025 | Coomer v. Lindell, D. Colo. | A brief with nearly thirty defective citations, including cases that do not exist | $3,000 against one lawyer and his firm, jointly; a separate $3,000 against a second lawyer | Order |
| 23 Jul 2025 | Johnson v. Dunn, N.D. Ala. | Two discovery motions with five hallucinated citations, generated by ChatGPT | Public reprimand of three lawyers; removal from the case; referral to the state bar; the order sent to clients, opposing counsel, judges in their other cases and every lawyer at the firm | Opinion |
| 23 Jul 2025 | Elizondo v. City of Laredo, S.D. Tex. | A response to a motion to dismiss citing four cases that were fictitious or materially wrong; the lawyer said a law clerk had used AI | $2,500; three hours of CLE including one on generative AI; the order served on the client | Order |
| 12 Sep 2025 | Noland v. Land of the Free, L.P., Cal. Ct. App. (published) | Appellate briefs in which 21 of 23 case quotations were fabricated | $10,000; the opinion served on the client; the clerk to notify the State Bar | Opinion |
| 22 Oct 2025 | Ma v. Cogdell Law Firm PLLC, Travis County District Court, Texas | A motion for reconsideration quoting passages that do not appear in the cited cases; the order names Westlaw’s AI feature | $2,000 in the other side’s fees; the motion struck; a letter explaining what went wrong, under Tex. Civ. Prac. & Rem. Code § 10.004 and Tex. R. Civ. P. 13 | Report (links the order) |
| 12 Dec 2025 | Couvrette v. Wisnovsky, D. Or. | Three summary judgment briefs citing 15 nonexistent cases and fabricated quotations from eight real ones | Briefs struck; $15,500 against one lawyer plus the other side’s fees; local counsel ordered to show cause; claims dismissed with prejudice; the order sent to the state bar | Order |
| 18 Feb 2026 | Fletcher v. Experian Information Solutions, Inc., 5th Cir. | A reply brief the court found was drafted largely with AI, with 16 fabricated quotations and five other serious misrepresentations | $2,500, citing the lawyer’s lack of candor in responding to the show-cause order | Opinion |
| 3 Jun 2026 | Lnu v. Blanche, 9th Cir. (published order) | Immigration briefs with nonexistent cases and misattributed quotations, later blamed on typing errors | $2,500 each for two lawyers; six-month suspension from practice before the court; the order sent to clients, judges and every lawyer at the firm; two years of sworn AI-use statements on every filing | Order |
One more order is often listed alongside these and is worth reading for a different reason. In Kohls v. Ellison (D. Minn., January 2025) an expert declaration filed by a state attorney general cited two academic articles that do not exist, drafted with GPT-4o. No lawyer was sanctioned; the court excluded the declaration. The fabrication does not have to be in your brief to cost you the evidence.
What every one of these had in common
Every one of these was found the same way: someone looked the citation up. The duty to do that before signing is not new, and none of these courts treated AI as changing it.
The later orders also punish the response as much as the filing. The Fifth Circuit’s sanction turned partly on a show-cause answer the court found was not forthcoming, and the Ninth Circuit’s on explanations it found untrue. When a citation turns out to be wrong, the answer to the court matters as much as the correction.
Two things prevent almost all of this:
- A cite-check before anything is filed, which resolves each citation before it trusts the name and confirms the case says what the brief says it says. The routine is in how to cite-check a brief, with the free tools that do the lookup.
- A written rule that no AI output is relied on until a person has verified it, so the check is the firm’s practice rather than one lawyer’s habit. Section 7 of the law firm AI policy template is that rule, ready to adopt.
New orders are added here once they have been checked against the order.
Sources and methodology
- Scope
- US federal and state courts, 2023 to 2026. The list is selective: it covers orders that imposed a sanction, referral or reprimand and that could be checked against the order itself or, where marked, two reliable reports. It is not a count of every case; the database linked below tracks those. Individual lawyers are not named here; the orders name them.
- How this was produced
- Each row was checked against the court's order, opened from the court's website, CourtListener's RECAP archive, govinfo, FindLaw or a copy of the filed order. Where the order could not be opened, the row says so and cites the reports it rests on. Sanctions are stated as ordered, not rounded. The tool is named only where the order names it.
- AI Hallucination Cases databaseDamien Charlotin
- Mata v. Avianca, Inc., No. 1:22-cv-01461, Opinion and Order on Sanctions (S.D.N.Y. June 22, 2023)FindLaw
- Park v. Kim, 91 F.4th 610 (2d Cir. 2024)FindLaw
- Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, Memorandum and Order (E.D. Tex. Nov. 25, 2024)Courthouse News Service (filed order)
- Kohls v. Ellison, No. 24-cv-3754, Order (D. Minn. Jan. 10, 2025)govinfo, U.S. Government Publishing Office
- Wadsworth v. Walmart Inc., Order on Sanctions (D. Wyo. Feb. 24, 2025)FindLaw
- Judge imposes sanctions for 'collective debacle' involving AI hallucinations and 2 law firmsABA Journal
- Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC, Order (S.D. Ind. May 28, 2025)Filed order
- Coomer v. Lindell, No. 1:22-cv-01129, Order (D. Colo. July 7, 2025)Filed order
- Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025)UC Berkeley School of Law (hosted copy)
- Elizondo v. City of Laredo, No. 5:25-cv-50, Order (S.D. Tex. July 23, 2025)CourtListener RECAP
- Noland v. Land of the Free, L.P., 114 Cal.App.5th 426 (2025)FindLaw
- Texas attorney sanctioned over AI-generated citations in filingBloomberg Law
- Couvrette v. Wisnovsky, No. 1:21-cv-00157, Opinion and Order (D. Or. Dec. 12, 2025)CourtListener RECAP
- Oregon federal judge hands down $110,000 penalty for AI errorsABA Journal
- Fletcher v. Experian Information Solutions, Inc., No. 25-20086 (5th Cir. Feb. 18, 2026)U.S. Court of Appeals for the Fifth Circuit
- Lnu v. Blanche, No. 24-4790, Order (9th Cir. June 3, 2026)U.S. Court of Appeals for the Ninth Circuit
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