The Verification TaxCourts are sanctioning lawyers for citations that do not exist.
Nine documented rulings, 2023 through 2026, each sourced to a primary court record. Not a rumor, not a round number, a tracked list.
The pattern, documented
What it looks like
This is not theoretical. Judges have fined, suspended, and dismissed claims over AI-fabricated citations across federal and state courts since 2023.
Couvrette v. Wisnovsky, No. 1:21-cv-00157-CL, U.S. District Court for the District of Oregon, decided December 12, 2025. Across three summary judgment briefs filed over roughly five months, lead counsel submitted 15 fabricated case citations plus 8 fabricated quotations, 23 fabrications total. The court called it "a notorious outlier in both degree and volume."
- The running count: one public database of court decisions that found reliance on AI-fabricated authority had passed 2,000 documented cases as of 14 September 2026, and it grows daily. Source
- The Couvrette bill: $15,500 payable to the court, plus the other side's fees, roughly $110,204 combined. The briefs were struck, the offending claims dismissed with prejudice, and the Oregon State Bar notified. Source
The record
Nine primary-sourced court sanctions for AI-fabricated citations, 2023 to 2026
Updated monthly; last checked 14 September 2026. Only cases with a primary docket source or a named, reputable secondary outlet were researched for this tracker. Two figures researched for it could not be independently confirmed and are left out rather than guessed at: the exact dollar sanction in Gonzalez v. Texas Taxpayers and Research Association, and whether the 2026 Coomer v. Lindell round has a docketed opinion separate from news coverage. The table below lists only the cases with a primary court or docket source.
| Case | Court | Date | What happened | Sanction |
|---|---|---|---|---|
| Mata v. Avianca, Inc. | S.D.N.Y. | Jun 22, 2023 | Brief cited six ChatGPT-fabricated cases; fake opinion excerpts produced when challenged. | $5,000 fine; letters to the client and each falsely named judge. |
| People v. Crabill | Colorado Presiding Disciplinary Judge | Nov 22, 2023 | Motion filed with fictitious ChatGPT-generated cases, unverified; blamed a legal intern. | One year one day suspension, stayed after 90 days, 2 year probation. |
| Park v. Kim | 2d Cir. | Jan 30, 2024 | Attorney cited a non-existent state appellate decision, admitted ChatGPT generated it. | Referred to the Grievance Panel; ordered to notify client. First federal circuit sanction of this kind. |
| Gauthier v. Goodyear Tire & Rubber Co. | E.D. Tex. | 2024 | Claude used to draft a response citing two non-existent cases and fabricated quotes. | $2,000 penalty plus mandatory CLE on generative AI. |
| Wadsworth v. Walmart Inc. | D. Wyo. | Feb 24, 2025 | Motions citing 9 cases, 8 nonexistent, generated via an internal firm AI tool. | Lead counsel fined $3,000, lost pro hac vice status; two others fined $1,000 each. |
| Kohls v. Ellison | D. Minn. | Jan 10, 2025 | An LLM-drafted expert declaration cited two nonexistent academic articles, misattributed a third. | No monetary fine; the declaration was struck and excluded. |
| Kaur v. Desso | N.D.N.Y. | Jul 9, 2025 | Fabricated quotations from Claude Sonnet 4, unverified, in an emergency habeas filing. | $1,000 fine; court found bad faith, weighed prompt admission and a CLE course as mitigating. |
| Couvrette v. Wisnovsky | D. Or. | Dec 12, 2025 | 15 fake case citations and 8 fake quotations across three briefs. | $15,500 to the court plus about $94,700 in the other side's fees; dismissal with prejudice; Bar referral. |
| Whiting v. City of Athens, Tennessee | 6th Cir. | Mar 13, 2026 | Consolidated appellate briefs with more than two dozen fake or misrepresented citations. | $15,000 punitive fine each, full appellate fees, double costs, disciplinary referral. |
Sources
- AI Hallucination Cases Database, Damien Charlotin (running count)
- Mata v. Avianca, Inc., CourtListener docket
- People v. Crabill, Colorado disciplinary filing
- Park v. Kim, court opinion
- Gauthier v. Goodyear Tire & Rubber Co., court filing
- Wadsworth v. Walmart Inc., court opinion
- Kohls v. Ellison, CourtListener docket
- Kaur v. Desso, court filing
- Couvrette v. Wisnovsky, Justia docket
- Whiting v. City of Athens, Tennessee, court opinion
What the bar and courts already require
What changes
ABA Formal Opinion 512, issued July 29, 2024, covers a lawyer's competence, confidentiality, candor to the tribunal, and supervisory duties when using generative AI. Several federal districts now require certification, following Judge Brantley Starr's 2023 standing order, that AI-drafted language was checked for accuracy by a human before filing.
One firm's reaction after a sanction landed:
Cite Check checks identified legal citations against available legal sources and surfaces citation and treatment information for attorney review. A successful match does not establish that an authority supports a particular proposition; attorneys should review the underlying authority before relying on it. The free verification workflow is the same check done by hand.
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