Last updated November 1, 2026. Version 1.0. Data cut: November 1, 2026.
Scope. This study covers US federal and state court orders only. Orders from 2023 and 2024 are a full census of the US cases in our discovery source. Orders from 2025 and 2026 come from random samples of 65 entries per year, so counts for those years describe a sample, and the per-year totals below are estimates. Every order counted here mentions AI, identifies fabricated or inaccurate content in a filing, and is one where the court itself attributes or suspects AI use.
Key findings
A warning was the most common outcome. 48 of 93 orders (52%, weighted 51%) stopped at a warning, a caution, or an express decision not to sanction, with no other measure.
Lawyers faced money sanctions far more often than self-represented parties. 11 of 36 orders involving attorney filings (31%) included a monetary sanction, compared with 5 of 54 orders involving self-represented filers (9%).
Stated amounts were mostly in the low thousands. Where an order stated a fixed amount (n = 11), the median was $2,710 and the range was $250 to $29,495.90. The top figure combines $6,000 in fines with a $23,495.90 fee and cost award in a single order. For attorney filings alone (n = 8), the median was $2,855.
Invented cases were the most common problem. 75 of 93 orders (81%) identify a citation to a case that does not exist. 34 (37%) identify a real case cited for something it does not hold, and 30 (32%) identify a fabricated or misquoted quotation.
Self-represented filers appear in most orders. 54 of 93 orders (58%, weighted 63%) involve a self-represented filer and 36 (39%, weighted 34%) an attorney.
The volume is large. We estimate that about 301 US tracker entries from 2025 (likely range 237 to 364) and about 505 from 2026 through November 1 (likely range 391 to 619) would meet the same strict rules.
How to read these numbers
We started from 179 tracker entries: all 49 US entries from 2023-2024, plus 65 randomly drawn entries for each of 2025 and 2026. We read the order behind each one. 119 met our inclusion rules (one more, an attorney-discipline matter, is reported separately). In 26 of those 119, the court did not itself tie the errors to AI. For example, only the opposing party raised AI, or the court said the cause did not matter. Those 26 are left out of the headline figures, which leaves the 93 orders this article reports on. The full 119-order comparison is in the methodology section and gives the same overall picture.
Raw percentages describe the 93 orders. Weighted percentages scale each sampled year up to its full tracker count, so 2025 and 2026 orders count for more. “Warning only” means the order’s only measure was a warning, a caution, or an express decision not to sanction. Every figure states its n.
Findings
1. How many orders, by year
By order date, the 93 orders break down as 3 in 2023, 18 in 2024, 36 in 2025 and 36 in 2026 through November 1. The 2025 and 2026 counts reflect the sample, not the full year. The table below scales them up.
| Tracker year | US tracker entries | Read | Met the strict rules | Estimated total meeting the rules |
|---|---|---|---|---|
| 2023-2024 | 49 | 49 (census) | 21 | 21 (a count, not an estimate) |
| 2025 | 528 | 65 | 37 (57%) | about 301 (range 237 to 364) |
| 2026, to Nov. 1 | 938 | 65 | 35 (54%) | about 505 (range 391 to 619) |
The ranges are 95% intervals on the pass rate (about 12 percentage points either way) applied to the tracker count. They also inherit any gaps in the tracker itself, since cases it never listed cannot be counted.
2. Who filed
| Filer | Orders (n = 93) | Raw share | Weighted share |
|---|---|---|---|
| Self-represented (pro se) | 54 | 58% | 63% |
| Attorney | 36 | 39% | 34% |
| Both (a represented party supplied the material and counsel filed it) | 1 | 1% | under 1% |
| Unclear from the order | 2 | 2% | 2% |
3. Warning only was the most common outcome
48 of 93 orders (52%, weighted 51%) were warning only. That includes 36 of 54 self-represented orders (67%) and 9 of 36 attorney orders (25%).
4. Every measure courts used
An order can carry several measures, so the rows add up to more than 93.
| Measure | Orders (n = 93) | Weighted share | Attorney (n = 36) | Pro se (n = 54) |
|---|---|---|---|---|
| Any warning (warning only, or a warning alongside another measure)¹ | 50 (54%) | 54% | 9 | 38 |
| Monetary sanction (fine, penalty or fee award) | 16 (17%) | 14% | 11 | 5 |
| Filing stricken | 12 (13%) | 13% | 6 | 6 |
| Referral or notice to the bar | 7 (8%) | 6% | 7 | 0 |
| Required CLE | 5 (5%) | 6% | 5 | 0 |
| Show-cause order, no sanction yet | 5 (5%) | 3% | 4 | 1 |
| Disqualification | 1 (1%) | 1% | 1 | 0 |
| Other (dismissal, filing restriction, reprimand, default judgment, issues waived, notice to clients or judges) | 22 (24%) | 24% | 11 | 11 |
5. Money sanctions
16 of 93 orders (17%, weighted 14%) included a monetary sanction: 11 of 36 attorney orders (31%) and 5 of 54 self-represented orders (9%).
11 of the 16 state a fixed amount. The other 5 award fees or costs to be set later.
The 11 stated amounts have a median of $2,710, a range of $250 to $29,495.90, and a total of $63,705.90.
Attorney filings (n = 8): median $2,855, range $2,000 to $29,495.90. Without the one order that combined fines with a fee award, the attorney range is $2,000 to $6,000.
Self-represented filings (n = 3): $250, $250 and $10,000. The $10,000 was ordered as damages for a frivolous appeal in Kruse v. Karlen (Mo. Ct. App. 2024).
6. What went wrong in the filings
An order can identify several problems.
| Problem identified by the court | All (n = 93) | Weighted | Attorney (n = 36) | Pro se (n = 54) |
|---|---|---|---|---|
| Case that does not exist | 75 (81%) | 72% | 29 (81%) | 44 (81%) |
| Real case, holding mischaracterized | 34 (37%) | 37% | 16 (44%) | 17 (31%) |
| Fabricated or misquoted quotation | 30 (32%) | 34% | 15 (42%) | 15 (28%) |
| Wrong citation details (reporter, page or court) | 4 (4%) | 6% | 1 | 2 |
| Inaccurate content, not itemized | 3 (3%) | 5% | 0 | 3 |
Attorney filings were flagged for misquoted or mischaracterized real authority more often than self-represented filings, in addition to invented cases. A citation that points to a real case can still be wrong.
7. Which courts
Federal courts issued 60 of the 93 orders (65%) and state courts 33 (35%). Appellate courts issued 27 (29%). The federal share may partly reflect which orders get published or posted online rather than where the problem occurs.
8. Courts rarely name the AI tool
Only 8 of 93 orders (9%) name a tool: ChatGPT in 3, and Google Bard, Claude, Microsoft Copilot, Perplexity and an AI research tool from a legal research vendor in 1 each. The rest say only that AI was used, admitted or suspected. In the two orders that named a paid or legal-specific tool, the court still struck the filing or imposed a monetary sanction.
9. Delegation did not move responsibility
In Thomas v. Commissioner (US Tax Court, 2024), counsel relied on a new paralegal’s draft without reviewing it. The court struck the memorandum and said “it is the attorney who signs a pleading who is responsible for its content.” In Mezu v. Mezu (Md. App. Ct. 2025), a non-lawyer law clerk used AI for research, and the court held that the lawyer who signed and submitted the brief was responsible. In United States v. Cohen (S.D.N.Y. 2024), a represented client supplied the citations to his lawyer. The court called the lawyer’s filing “embarrassing and certainly negligent” but declined to sanction because it found no bad faith.
10. How the lawyer responded mattered in some orders
In Elizondo v. City of Laredo and Mattox v. Product Innovation Research, the courts cited counsel’s candid acknowledgment of the problem as a reason for a lighter sanction. In Evans v. Execushield, the court declined to send its order to the State Bar because the attorney took responsibility. In Billups v. Louisville Municipal School District, where counsel had kept using AI without verifying its output, the court disqualified counsel and referred the matter to the bar.
What courts say
“Technological advances are commonplace and there is nothing inherently improper about using a reliable artificial intelligence tool for assistance. But existing rules impose a gatekeeping role on attorneys to ensure the accuracy of their filings.” Mata v. Avianca, Inc., No. 1:22-cv-01461 (PKC) (S.D.N.Y. June 22, 2023).
“At the very least, the duties imposed by Rule 11 require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely.” Park v. Kim, No. 22-2057 (2d Cir. Jan. 30, 2024).
“A lawyer’s or a self-represented party’s future filing in this court containing GAI-generated hallucinations may result in sanctions.” Al-Hamim v. Star Hearthstone, LLC, 2024COA128, No. 24CA0190 (Colo. App. Dec. 26, 2024).
“The Court will not accept AI as an excuse for inaccuracies and will hold the parties responsible for whatever filings appear with their signatures.” Mathew v. Verma, No. 4:25-cv-13262 (E.D. Mich. Aug. 10, 2026).
“Counsel’s submission of AI-generated content without verifying the accuracy of the cited authorities is a serious breach of several Model Rules of Professional Conduct.” Progressive Northern Insurance Co. v. Flores, No. 2:24-cv-02207-RFB-BNW (D. Nev. June 18, 2026).
What this means for firms
These are practical takeaways from the orders, not legal advice. Check your own court’s rules and standing orders.
Check every authority, not just whether it exists. More than a third of orders involved real cases cited for the wrong point, and about a third involved quotations that the cited case does not contain. A cite check that only confirms a case is real misses those.
Open the source for every quotation and pinpoint. Misquotes and wrong page cites are the errors a quick existence check is least likely to catch.
The signer owns the filing. Courts held the signing lawyer responsible when a paralegal, a law clerk or the client supplied the material. Build review of delegated drafts into the workflow before anything is signed.
Read local rules on AI. Some courts and judges have standing orders on AI use or disclosure.
If an error surfaces, deal with it directly. In several orders, a candid acknowledgment and prompt correction weighed toward a lighter outcome. Continued unverified use after a problem was flagged drew the harshest response in the set.
Expect to see this on the other side, too. Most orders involve self-represented filers. Checking the authorities in an opponent’s filing is part of the same habit.
Methodology
Discovery source. Candidate cases came from Damien Charlotin’s AI Hallucination Cases database, downloaded November 1, 2026 (CC BY 4.0). We used the tracker only to find cases. Every row in our dataset was checked against the order itself.
Inclusion criteria. An order is included only if all of these hold:
It comes from a US federal or state court.
The source is the court’s own order, opinion, ruling, report and recommendation, or tentative ruling.
The order text mentions artificial intelligence, generative AI or a named AI tool, as an admission, a finding, a suspicion or a caution.
The order itself identifies fabricated or inaccurate content, such as a nonexistent case, a misquote or a mischaracterized holding.
The filer is counsel or a party, not an expert or a judge.
The order is dated January 1, 2023 or later, through the data cut.
Strict set vs. full set. All 119 included orders appear in the CSV. A flag (weak_link) marks the 26 where the court does not itself attribute or suspect AI: AI was raised only by the other side, the court spoke only conditionally (“to the extent”), the court said the cause did not matter, AI appeared only in a general statement or a citation to another case, or only a separate opinion mentioned AI. This article reports the 93 strict orders. The full set gives similar results:
| Figure | Strict set (n = 93) | Full set (n = 119) |
|---|---|---|
| Warning only | 48 (52%, weighted 51%) | 68 (57%, weighted 58%) |
| Monetary sanction | 16 (17%, weighted 14%) | 16 (13%, weighted 11%) |
| Monetary sanction, attorney filings | 11 of 36 (31%) | 11 of 41 (27%) |
| Monetary sanction, pro se filings | 5 of 54 (9%) | 5 of 75 (7%) |
| Stated amounts | n = 11, median $2,710 | the same 11 |
| Case that does not exist | 75 (81%, weighted 72%) | 97 (82%, weighted 73%) |
| Self-represented filers | 54 (58%, weighted 63%) | 75 (63%, weighted 67%) |
| 2025 estimate | about 301 | about 349 |
| 2026 estimate (to Nov. 1) | about 505 | about 649 |
Sample and weighting. The 2023-2024 stratum is a census of all 49 US tracker entries. For 2025 (528 entries) and 2026 (938 entries, excluding two private arbitration awards), we drew two simple random samples per year, 65 entries in total each, without replacement. Each 2025 row carries a weight of 528/65 and each 2026 row 938/65. Census rows carry a weight of 1. Years in the tables use the order date. Weighting follows the year the tracker assigned.
Coding. Sanctions were coded from the order’s operative language, not from the tracker’s summary, and where the two differ the row note says so. A dollar amount is recorded only when the order states a fixed amount tied to the AI-related conduct. Where one order sanctions several lawyers, or adds a fixed fee award to a fine, the amount is the sum and the note itemizes it. Unrelated amounts, such as discovery sanctions, are noted but not coded. The AI tool is recorded only when the order names it.
Exclusions. 59 sampled entries did not meet the rules and are listed with reasons in a separate file. The most common reason (32 entries) is that the order never ties the errors to AI. One attorney-discipline matter (People v. Crabill, Colorado Presiding Disciplinary Judge, 2023) is not a court order in litigation, so it sits in its own file and counts in no statistic.
Limitations
Published orders only. Bench rulings that were never written up, sealed matters and orders never posted online are missing. Many lower state court orders never reach a database.
One discovery source. Cases the tracker never listed cannot appear here, and its coverage may lean toward federal courts.
A strict AI test. Orders about fake citations that never mention AI are excluded even when AI use is likely. The dataset undercounts on purpose.
Sampling error. Each 2025 and 2026 estimate rests on 65 sampled entries, so the pass rate could be about 12 points higher or lower.
Small subgroups. Figures for stated amounts (n = 11) and named tools (n = 8) describe a handful of orders and should not be read as typical.
Copies of orders. About half the links (49 of 93) point to a court’s own site or govinfo.gov; the rest point to copies hosted by the tracker, CourtListener or Justia. Three order dates come from the tracker or a citation because the date is not printed in the extracted text, and the row note says so.
Not an evaluation. Coding records what each order says. It is not a view on whether any sanction was right or on any lawyer or party.
Download the data
ai-sanctions-2023-2026.csv: all 119 included orders, one row each, with the
weak_linkflag that defines the strict set. Each row links to the order.excluded-unverified.csv: the 59 sampled entries that were not included, with the reason for each.
attorney-discipline.csv: the one attorney-discipline matter, reported separately.
DATA-DICTIONARY.md: every column and code.
The 93 orders
Measures are coded from each order. Amounts appear where the order states one.
| # | Case | Court | Order date | Filer | Measures coded | Source |
|---|---|---|---|---|---|---|
| 1 | Scott v. Federal National Mortgage Association | Maine Superior Court, Cumberland County | 2023-06-14 | pro se | monetary; other (dismissal) | order |
| 2 | Mata v. Avianca, Inc. | U.S. District Court, S.D.N.Y. | 2023-06-22 | attorney | monetary ($5,000); other (letters to client and judges) | order |
| 3 | Ex parte Lee | Texas Court of Appeals, Tenth District (Waco) | 2023-07-19 | attorney | warning only | order |
| 4 | Matter of Samuel | New York Surrogate's Court, Kings County | 2024-01-11 | attorney | striking; show-cause only | order |
| 5 | Park v. Kim | U.S. Court of Appeals, Second Circuit | 2024-01-30 | attorney | referral to bar; other (provide order to client) | order |
| 6 | Kruse v. Karlen | Missouri Court of Appeals, Eastern District | 2024-02-13 | pro se | monetary ($10,000); other (dismissal) | order |
| 7 | United States v. Cohen | U.S. District Court, S.D.N.Y. | 2024-03-20 | both | warning only | order |
| 8 | Plumbers & Gasfitters Union Local No. 75 Health Fund v. Morris Plumbing, LLC | U.S. District Court, E.D. Wisconsin | 2024-04-18 | attorney | warning only | order |
| 9 | Dowlah v. Professional Staff Congress (PSC-CUNY) | New York Appellate Division, First Department | 2024-05-30 | pro se | warning only | order |
| 10 | Dukuray v. Experian Information Solutions | U.S. District Court, S.D.N.Y. (magistrate judge R&R) | 2024-07-26 | pro se | warning only | order |
| 11 | Martin v. Hawai'i | U.S. District Court, D. Hawai'i | 2024-08-20 | pro se | warning only | order |
| 12 | Rasmussen v. Rasmussen | California Superior Court, Sonoma County (tentative ruling) | 2024-08-23 | attorney | show-cause only | order |
| 13 | Transamerica Life Insurance Co. v. Williams | U.S. District Court, D. Arizona | 2024-09-06 | pro se | warning only | order |
| 14 | Jones v. Simploy, Inc. | Missouri Court of Appeals, Eastern District | 2024-09-24 | pro se | warning only | order |
| 15 | Thomas v. Commissioner of Internal Revenue | United States Tax Court | 2024-10-23 | attorney | striking | order |
| 16 | Mortazavi v. Booz Allen Hamilton, Inc. | U.S. District Court, C.D. California | 2024-10-30 | attorney | monetary ($2,500); referral to bar | order |
| 17 | Chan v. Khermani LLC | Wyoming Chancery Court | 2024-11-14 | pro se | warning only | order |
| 18 | Gauthier v. Goodyear Tire & Rubber Co. | U.S. District Court, E.D. Texas | 2024-11-25 | attorney | monetary ($2,000); CLE; other (provide order to client) | order |
| 19 | Rubio v. District of Columbia Department of Human Services | U.S. District Court, D.D.C. | 2024-12-03 | pro se | warning only | order |
| 20 | Letts v. Avidien Technologies, Inc. | U.S. District Court, E.D. North Carolina (magistrate judge M&R) | 2024-12-16 | pro se | warning only | order |
| 21 | Al-Hamim v. Star Hearthstone, LLC | Colorado Court of Appeals | 2024-12-26 | pro se | warning only | order |
| 22 | Evans v. Execushield, Inc. | California Superior Court, Alameda County | 2025-03-10 | attorney | other (class certification denied on counsel adequacy) | order |
| 23 | Arnaoudoff v. Tivity Health Inc. | U.S. District Court, D. Arizona | 2025-03-11 | pro se | warning only | order |
| 24 | Stevens v. BJC Health System | Missouri Court of Appeals, Eastern District | 2025-03-18 | pro se | warning only | order |
| 25 | Sanders v. United States | U.S. Court of Federal Claims | 2025-03-31 | pro se | warning only | order |
| 26 | Mid Central Operating Engineers Health & Welfare Fund v. HoosierVac LLC | U.S. District Court, S.D. Indiana | 2025-05-28 | attorney | monetary ($6,000) | order |
| 27 | Crespo v. Tesla, Inc. | U.S. District Court, S.D. Florida | 2025-06-30 | pro se | monetary; other (written apology) | order |
| 28 | Elizondo v. City of Laredo | U.S. District Court, S.D. Texas | 2025-07-23 | attorney | monetary ($2,500); CLE | order |
| 29 | In re Richburg | U.S. Bankruptcy Court, D. South Carolina | 2025-08-27 | attorney | CLE | order |
| 30 | Nixon v. Ken Ganley Ford West | U.S. District Court, N.D. Ohio | 2025-09-03 | pro se | warning only | order |
| 31 | United States v. Brewer | U.S. District Court, M.D. Florida | 2025-09-11 | attorney | show-cause only | order |
| 32 | Sigal v. Croner | Nevada District Court, Clark County | 2025-09-22 | attorney | warning only | order |
| 33 | In re Marriage of D.X. and S.P. | California Court of Appeal, Sixth District | 2025-09-30 | pro se | warning only | order |
| 34 | Ader v. Ader | New York Supreme Court, New York County | 2025-10-01 | attorney | monetary; referral to bar | order |
| 35 | Kasso v. Police Officers' Federation of Minneapolis | U.S. District Court, D. Minnesota | 2025-10-21 | pro se | warning only | order |
| 36 | Mattox v. Product Innovation Research | U.S. District Court, E.D. Oklahoma | 2025-10-22 | attorney | striking; monetary ($29,495.90); other (public reprimand) | order |
| 37 | University Mall v. Okorie | U.S. District Court, S.D. Mississippi | 2025-10-22 | pro se | other (pre-filing injunction) | order |
| 38 | Mezu v. Mezu | Appellate Court of Maryland | 2025-10-29 | attorney | referral to bar | order |
| 39 | Borsody v. Frontier Heritage Communities | U.S. District Court, D. Kansas | 2025-11-04 | pro se | warning only | order |
| 40 | In re M.O.W. | Texas Court of Appeals, Third District (Austin) | 2025-11-07 | pro se | warning only | order |
| 41 | Shelton v. Parkland Health | U.S. District Court, N.D. Texas | 2025-11-10 | attorney | other (reprimand) | order |
| 42 | United States v. Czartorski | U.S. District Court, W.D. Kentucky | 2025-11-10 | attorney | show-cause only | order |
| 43 | LaRoche v. Sterett | Vermont Supreme Court | 2025-11-13 | attorney | other (file copy of order in all pending cases) | order |
| 44 | Montoya Cabanas v. Bondi | U.S. District Court, S.D. Texas | 2025-11-13 | attorney | warning only | order |
| 45 | Lewis v. Eagle County Government | U.S. District Court, D. Colorado | 2025-11-14 | attorney | monetary ($3,000); other (case terminated) | order |
| 46 | Moorehead v. Goodwill Industries of Northeast Texas | U.S. District Court, E.D. Texas | 2025-11-18 | pro se | warning only | order |
| 47 | Zero Point MGMT v. Chase Bank | U.S. District Court, S.D.N.Y. | 2025-11-24 | pro se | warning only | order |
| 48 | Andre v. Warden, FCI Danbury | U.S. District Court, D. Connecticut | 2025-11-25 | pro se | striking; warning | order |
| 49 | Magee v. New Balance Athletics, Inc. | U.S. District Court, E.D. Arkansas | 2025-12-02 | pro se | striking; show-cause only | order |
| 50 | Allston v. DeSantis | U.S. District Court, M.D. Florida | 2025-12-04 | pro se | warning only | order |
| 51 | Sharky's Sports Bar v. Village of Mt. Morris | U.S. District Court, N.D. Illinois | 2025-12-10 | unclear | warning only | order |
| 52 | Kulkarni v. Merit Systems Protection Board | U.S. Court of Appeals, Federal Circuit | 2025-12-15 | pro se | striking | order |
| 53 | Holmes Family Trust v. Multnomah County Assessor | Oregon Tax Court, Magistrate Division | 2025-12-16 | unclear | warning only | order |
| 54 | Zhang v. National Public Radio, Inc. | U.S. District Court, D.D.C. | 2025-12-18 | attorney | striking; monetary | order |
| 55 | Billups v. Louisville Municipal School District | U.S. District Court, N.D. Mississippi | 2025-12-19 | attorney | disqualification; referral to bar; other (copy of order to presiding judges; firm audit) | order |
| 56 | Allen v. Amazon | U.S. District Court, N.D. Texas | 2025-12-23 | pro se | warning only | order |
| 57 | M.T. Real Estate Investment Inc. v. Servis One | U.S. District Court, D. Nevada | 2025-12-30 | attorney | striking; monetary; referral to bar | order |
| 58 | Peters v. Banner Health | U.S. District Court, S.D. Texas (magistrate judge recommendation) | 2026-01-15 | pro se | other (recommended dismissal with prejudice) | order |
| 59 | SEC v. Nantomah | U.S. District Court, E.D. Wisconsin | 2026-01-30 | pro se | striking | order |
| 60 | Flycatcher v. Affable Avenue | U.S. District Court, S.D.N.Y. | 2026-02-05 | attorney | striking; other (default judgment) | order |
| 61 | Gonzales Davila v. Roblen | U.S. District Court, D. Connecticut | 2026-02-06 | attorney | CLE; other (written article for the state legal community) | order |
| 62 | Pena v. Wells Fargo | U.S. District Court, S.D. Florida (magistrate judge R&R) | 2026-02-19 | pro se | warning only | order |
| 63 | In re H.K. (termination of parental rights) | Arizona Court of Appeals, Division One | 2026-02-25 | attorney | referral to bar | order |
| 64 | United States v. Simmons | U.S. District Court, E.D. North Carolina | 2026-03-10 | attorney | warning only | order |
| 65 | Hartmann v. Davidson | U.S. District Court, N.D. Texas | 2026-03-12 | pro se | warning only | order |
| 66 | Gouveia v. Meridian Financial Investments | Florida Fourth District Court of Appeal | 2026-03-25 | pro se | warning only | order |
| 67 | Zavadovsky v. Republic of Austria | U.S. District Court, D.D.C. | 2026-03-31 | pro se | warning only | order |
| 68 | In re W.G. | Iowa Court of Appeals | 2026-04-01 | pro se | striking | order |
| 69 | Jordan v. United States | U.S. District Court, C.D. California | 2026-04-06 | pro se | warning only | order |
| 70 | Strong v. Zubha Pop Foods LLC | Illinois Appellate Court, First District | 2026-04-15 | pro se | striking; other (appeal dismissed) | order |
| 71 | Jarvis v. County of Teton | U.S. Court of Appeals, Tenth Circuit | 2026-04-24 | pro se | warning only | order |
| 72 | In re W.B. | California Court of Appeal, Fifth District | 2026-04-29 | pro se | warning only | order |
| 73 | Johnson v. Nationstar Mortgage, LLC | U.S. District Court, D. Maryland | 2026-04-30 | pro se | warning only | order |
| 74 | Jones v. Department of the Army | U.S. Court of Appeals, Federal Circuit | 2026-05-13 | pro se | warning only | order |
| 75 | Chakma v. Sushi Katsuei, Inc. | U.S. District Court, S.D.N.Y. | 2026-05-19 | attorney | monetary ($2,710) | order |
| 76 | Sherwood v. County of Botetourt | U.S. District Court, W.D. Virginia | 2026-05-20 | attorney | warning only | order |
| 77 | Avery v. Beauzil | Florida Fourth District Court of Appeal | 2026-05-27 | pro se | other (filing restriction) | order |
| 78 | Christ Apostolic Temple, Inc. v. Sinegal | Iowa Court of Appeals | 2026-05-27 | pro se | warning only | order |
| 79 | Matter of Julien v. Arthur | New York Appellate Division, Second Department | 2026-05-27 | pro se | monetary ($250) | order |
| 80 | Progressive Northern Insurance Co. v. Flores | U.S. District Court, D. Nevada | 2026-06-18 | attorney | warning only | order |
| 81 | Zhdanovich-Doty v. Provident Life and Accident Insurance Co. | U.S. District Court, N.D. California | 2026-06-22 | attorney | warning only | order |
| 82 | Swinney v. JHOC, Inc. | Mississippi Circuit Court, Copiah County | 2026-07-06 | attorney | warning only | order |
| 83 | Pamon v. United States Postal Service | U.S. District Court, N.D. Texas | 2026-07-22 | pro se | warning only | order |
| 84 | Ponder v. BCG Equities, LLC | U.S. District Court, E.D. Michigan | 2026-07-27 | pro se | warning only | order |
| 85 | Merritt v. American Home Shield | Tennessee Court of Appeals (Jackson) | 2026-08-03 | pro se | other (issues waived) | order |
| 86 | Mathew v. Verma | U.S. District Court, E.D. Michigan | 2026-08-10 | pro se | warning only | order |
| 87 | Voyton v. Voyton | U.S. District Court, M.D. Pennsylvania | 2026-08-11 | pro se | warning; other (AI-use affidavit required) | order |
| 88 | In re Marriage of Lindsay and Dillon | California Court of Appeal, Fourth District, Division One | 2026-08-19 | pro se | other (costs on appeal denied) | order |
| 89 | Kelly v. Financial Industry Regulatory Authority | U.S. District Court, D. Nevada | 2026-08-19 | pro se | warning only | order |
| 90 | Perez v. Schaal | California Superior Court, Sacramento County | 2026-08-21 | pro se | warning only | order |
| 91 | LPC Commercial Services, LLC v. Ar-Razzaaq Properties, LLC | Court of Appeals of Virginia | 2026-08-25 | attorney | CLE | order |
| 92 | R.M. v. Mohr | Oregon Court of Appeals | 2026-09-23 | pro se | monetary ($250) | order |
| 93 | Washington v. Justice | Florida Second District Court of Appeal | 2026-10-07 | pro se | other (filing restriction) | order |
Frequently asked questions
How often do courts sanction lawyers for AI-generated fake citations?
In the 93 strict orders, 24 of 36 attorney orders (67%) imposed at least one measure beyond a warning, and 11 of 36 (31%) included a monetary sanction. Other measures included striking the filing, bar referral, required CLE and disqualification. Another 3 attorney orders were show-cause orders with no sanction decided yet, and 9 were warning only.
How large are AI hallucination fines?
Where an order stated a fixed amount (n = 11), the median was $2,710 and the range was $250 to $29,495.90. The attorney median was $2,855 (n = 8). Most stated amounts fell between $2,000 and $6,000.
What is the most common AI error courts find?
A citation to a case that does not exist, found in 75 of 93 orders (81%). Real cases cited for the wrong point (34 orders) and fabricated or misquoted quotations (30 orders) come next.
Do self-represented litigants get sanctioned for AI errors?
Sometimes, but usually less severely. 36 of 54 orders involving self-represented filers (67%) ended in a warning only, and 5 of 54 (9%) included a monetary sanction.
Does using a paid or legal-specific AI tool protect a filer?
No order in the set treated the choice of tool as an excuse. Courts named a tool in only 8 of 93 orders. In the one involving a paid version of a general AI tool, the filing was stricken. In the one involving an AI research tool from a legal research vendor, the court imposed a monetary sanction.
Who is responsible when a paralegal, clerk or client supplies the bad citation?
In the orders that addressed it, courts looked to the lawyer who signed the filing.
How many AI hallucination orders are there in the US?
We estimate about 301 tracker entries from 2025 and about 505 from 2026 through November 1 would meet our strict rules, with wide ranges (237 to 364 and 391 to 619). These figures cover only cases the tracker found.
Why 93 orders and not more?
We verified 119 orders. In 26, the court did not itself attribute the errors to AI, so they are left out of the headline figures. Both sets are in the CSV.
Is this legal advice?
No. It is a factual summary of published court orders. Each row links to the order.
How often is this updated?
Quarterly. This version uses data through November 1, 2026.
How to cite
Turbo Law. AI hallucination sanctions in US courts, 2023-2026: what 93 court orders show. Version 1.0, data cut November 1, 2026. https://turbolaw.ai/research/ai-sanctions-2023-2026
Discovery data: Damien Charlotin, AI Hallucination Cases database, damiencharlotin.com/hallucinations (CC BY 4.0).
Corrections
If you spot an error in a row or know of an order we missed, please contact us with the case name and a link to the order. Confirmed corrections go into the next quarterly update and its change log.
About this research
This dataset was compiled by Turbo Law, a legal technology company that works with litigation teams. Discovery leads came from Damien Charlotin’s AI Hallucination Cases database (CC BY 4.0), and every included row was checked against the order. The CSV, methodology and excluded list may be reused with attribution.
Not legal advice. This page summarizes what published court orders say. It is not legal advice and does not create an attorney-client relationship. For advice about a specific matter, consult a licensed attorney in your jurisdiction.
¹ “Warning only” counts orders whose only measure is a warning, a caution or an express decision not to sanction (48 of 93). “Any warning” also counts 2 orders that paired a warning with another measure (a stricken filing in Andre v. Warden, and a required AI-use affidavit in Voyton v. Voyton), for 50 of 93.
