Flood of AI-Related Sanctions Persist
More than 225 Federal Cases (and more than $225K in Attorney Fees in Four Cases) Highlight the First Quarter 2026 Slop Docket
A Cook County Circuit Court imposed a monumental sanction against a big law firm to close out 2025.[1] In a post-trial motion, the CHA’s brief included fourteen instances of misrepresented legal propositions; the court observed that these errors were not mere nuances but blatant fabrications. The court ordered an attorney to pay $10,000 and the law firm to pay $49,500 to opposing counsel in the award of attorney fees. The sanction award was another example, highlighting the ethical risks of using AI tools in legal research and the necessity for maintaining professionalism and accuracy in legal filings.
In 2025, federal courts addressed 367 cases with AI-induced misrepresentations, misquotations, fabrications, and other assorted faux pas. A forthcoming article, The Slop Docket: Gen AI’s War on Legal Truth, features AI-generated mishaps in federal cases beginning with Mata v. Avianca[2] in 2023 and running through the end of 2025. A couple of the misadventures included an AI train wreck in Florida,[3] resulting in an award of more than $85,000 in attorney fees and a referral for disciplinary action, as well as a pair of attorneys stumbling through self-inflicted AI-laced errors in three district courts. (One of the cases involved the defense of the MyPillow guy in a defamation case.)[4]
The AI-atrocity exhibition continued in the first quarter of 2026, with more than 220 cases flooding federal dockets through March 31, 2026. Some noteworthy cases were Whiting v. City of Athens,[5] Couvrette v. Wisnovsky,[6] Rivera v. Triad Properties,[7] and Heimkes v. Fairhope Motorcoach Resort.[8]
In Whiting, the court found that the appellants' attorneys engaged in misconduct by submitting briefs that included fake case citations and misrepresentations of the record. In imposing sanctions, the court emphasized that the submission of fake cases and factual misrepresentations forced it to individually verify each citation (a significant burden). The court ordered the attorneys to reimburse the appellees for their attorney fees (in excess of $30,000). Additionally, the court ordered the attorneys to pay double costs to the appellees. Significantly, the court imposed punitive sanctions totaling $15,000 against each attorney. Finally, the court directed the clerk to forward a copy of the order to the chief judge for consideration of disciplinary proceedings.
In Couvrette, the court found that the plaintiffs’ summary judgment briefing contained the classic hallmarks of hallucinated authorities often associated with improper use of AI or intentional misrepresentation. The defendants’ briefing repeatedly flagged the misconduct and formed the basis for a motion for sanctions. The court identified additional rule violations in the plaintiffs’ filings, including a false word-count certification, improper formatting and filing of exhibits/declarations, and noncompliance with summary judgment factual citation requirements. The court sanctioned the plaintiffs and their pro hac vice counsel for repeated violations of court rules by imposing a $15,500 monetary sanction, striking the summary judgment briefing, and dismissing the claims with prejudice. Additionally, the court found that local counsel willfully violated local rules by failing to “meaningfully participate” as local counsel, despite being warned to do so to help ensure compliance. The court ordered local counsel to pay 15 percent of the defendants’ reasonable fees and costs tied to the summary judgment briefing (more than $14,000). The court ordered the remaining attorney fees (in excess of $80,000) to be paid by pro hac vice counsel.
In Rivera, the plaintiff's attorney used AI to draft court documents that contained false statements of law, including nonexistent and fabricated citations. The court imposed several sanctions on the attorney and his law firm. First, the court suspended the attorney from practicing in the Northern District of Alabama for three months. The court disqualified the attorney and the firm from further participation in the case and referred the matter to licensing authorities for further proceedings. The court ordered the attorney and the firm to pay the defendants' attorney fees (amounting to more than $47,000). Finally, the court issued a public reprimand for the attorney and the firm.
In Heimkes, the plaintiff's attorney filed several pleadings containing fabricated citations and false statements of law, which he failed to verify or correct before submission. The court determined that the attorney's conduct amounted to bad faith and imposed sanctions under its inherent authority, as well as under Rule 11 and the Alabama Rules of Professional Conduct. In making the determination, the court noted that the attorney's misconduct went beyond mere recklessness, and his actions caused significant delays and wasted resources. First, the court reprimanded the attorney by ordering the filing of the Memorandum Opinion and Order in any case in which the attorney appears as counsel for twelve months, and by providing a copy to any jurisdiction where he is licensed to practice law. Next, the court directed the clerk to send a copy to the general counsel of the Alabama State Bar and the chief judges for the Northern, Middle, and Southern Districts of Alabama. Significantly, the court ordered the attorney to pay more than $55,000 in attorney fees to opposing counsel for the time spent addressing the AI fabrications. Finally, the court referred the matter to the Alabama State Bar for further proceedings, specifically recommending that the attorney be found incompetent to practice law.
The flood shows no sign of receding. With more than 220 federal cases already logged in the first quarter of 2026 alone, the AI hallucination docket has become less a cautionary tale than a standing feature of American jurisprudence—a grim, self-replenishing archive of fabricated citations, misrepresented holdings, and blatant falsehoods submitted, apparently, with the serene confidence of the utterly unverified. Sanctions escalate: six figures here, a suspension there, a bar referral forwarded to whichever authority is still paying attention. The legal profession has had its Mata moment, its Johnson[9] moment, its ByoPlanet train wreck—and still the slop flows. What we are witnessing is not merely professional negligence at scale; it is, as Hannah Arendt would recognize, the gradual normalization of a world in which plausible-sounding falsehood is indistinguishable from truth, and in which the machinery of justice grinds forward, authenticating whether basic reality exists. Machines can assemble words, but we cannot believe in them. That burden (inconvenient, irreplaceable, and entirely human) remains with the lawyer who signs the brief.
[1] Jordan v. Chicago Housing Authority, No. 2022 L 000095 (Ill. Cir. Ct. Dec. 5, 2025).
[2] Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023).
[3] ByoPlanet Int’l, LLC v. Gilstrap, 792 F. Supp. 3d 1341 (S.D. Fla. 2025).
[4] Coomer v. Lindell, No. 22-cv-01129, 2026 WL 817370 (D. Colo. Mar. 25, 2026).
[5] Whiting v. City of Athens, 170 F.4th 455 (6th Cir. 2026).
[6] Couvrette v. Wisnovsky, No. 21-cv-00157, 2026 WL 870387 (D. Or. Mar. 30, 2026).
[7] Rivera v. Triad Properties Corp., No. 24-cv-01802, 2026 WL 915744 (N.D. Ala. Mar. 31, 2026).
[8] Heimkes v. Fairhope Motorcoach Resort Condo. Owners Ass’n, Inc., No. 22-cv-00448, 2026 WL 883120 (S.D. Ala. Mar. 31, 2026).
[9] Johnson v. Dunn, 792 F. Supp. 3d 1241 (N.D. Ala. 2025).