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AI Fake Citation Sanctions: Court Decisions Tracker (2027)

Independently fact-checkedLaw current as of November 6, 2026By Recording Law Editorial Team26 min read

Independently fact-checked against primary sources (last audited November 6, 2026). · Law checked current as of November 6, 2026. · 16 primary sources cited on this page. How we verify our legal content

AI Fake Citation Sanctions: Court Decisions Tracker (2027)

Courts have sanctioned both lawyers and self-represented litigants for filing fake, AI-generated citations, with penalties ranging from warnings and orders to certify every future citation, to fines paid to the court, orders to pay the other side's legal fees, referrals to bar and grievance authorities, disqualification from the case and suspension of the right to practice before a court. The largest figure among the decisions on this page is in an Oregon federal case, Couvrette v. Wisnovsky, where the court ordered one lawyer to pay $15,500 to the court in December 2025 and, in March 2026, ordered him and his local co-counsel to pay the defendants $94,704.38 in fees and costs between them.

Last updated November 6, 2026: This is a selected tracker of 13 sanctions decisions we read in full, newest first. It is not a complete count of fake-citation cases.

This page covers sanctions in US federal and state courts for citing cases, quotations or authorities that do not exist. For the court rules on using AI in filings, see our AI in court guide; for what each state's courts require, see court AI rules by state.

AI fake citation sanctions tracker

Each row is a decision we read, dated by the order itself. "AI finding" records what the court said about AI use, including where it made no finding. Dollar figures are as the orders state them.

Timeline of nine selected fake AI citation sanctions, from Mata v. Avianca in June 2023 to Payne v. State in May 2026, ranging from referrals with no fine to fines, fee awards and a suspension.
A selection of decisions from this page, not every case. Sanctions ranged from referrals with no fine to fines, fee awards and a six-month suspension.
DateCase and courtWho was sanctionedSanctionLegal basisAI finding
May 5, 2026Payne v. State, No. S26A0459, Supreme Court of GeorgiaClayton County assistant district attorney Deborah Leslie (prosecutor in a murder appeal); the district attorney's office was admonishedPrivilege to practice before the Supreme Court of Georgia suspended for six months, with reinstatement conditioned on 12 CLE hours beyond the regular requirement; the trial court's order denying a new trial, largely prepared by the prosecutor, was vacated and remandedThe court's inherent authority and its Supreme Court Rule 7, citing OCGA 15-1-3(4)The prosecutor acknowledged in a March 27, 2026 affidavit using AI software to draft the State's briefs and the proposed order
December 12, 2025 and March 23, 2026Couvrette v. Wisnovsky, No. 1:21-cv-00157, D. Or.Plaintiffs' pro hac vice counsel Stephen Brigandi and Oregon local counsel Timothy Murphy; the court also found the plaintiffs shared responsibility and dismissed their claimsDecember 2025: Brigandi ordered to pay $15,500 to the Clerk, briefs struck, plaintiffs' claims dismissed with prejudice, order sent to the Oregon State Bar. March 2026: defendants' fees and costs of $94,704.38 found reasonable, with Brigandi to pay 85% ($80,498.72) and Murphy 15% ($14,205.66)Federal Rule of Civil Procedure 11(b) and the court's Local RulesThe court described "Plaintiffs' misuse of generative artificial intelligence"; counsel did not admit AI use
March 13, 2026Whiting v. City of Athens, Nos. 24-5918/5919/25-5424, Sixth Circuit (recommended for publication)Appellant's lawyers Van R. Irion and Russ EgliFull appellate attorney fees to the appellees, jointly and severally, double costs, $15,000 each to the court as punitive sanctions, and a copy to the chief judge to consider discipline under Sixth Circuit Local Rule 46Federal Rule of Appellate Procedure 38 and the court's inherent authorityThe lawyers did not answer the court's direct question whether they used generative AI; the court made no finding that they did
February 18, 2026Fletcher v. Experian Information Solutions, Inc., No. 25-20086, Fifth Circuit (published)Appellant's lawyer Heather Hersh$2,500 payable to the courtFederal Rule of Appellate Procedure 46(c) and inherent powerThe court found she used generative AI to draft a substantial portion, if not all, of her reply brief; she admitted AI use only when asked directly
December 1, 2025Lothamer Tax Resolution, Inc. v. Kimmel, No. 1:25-cv-00579, W.D. Mich.The pro se defendant$2,900 ($100 for each of 29 false citations), with a warning that the amount per violation would double if repeatedRule 11 and, alternatively, the court's inherent powers (bad faith)He denied using AI; the court called his response "inadequate and not credible" but made no finding that AI was used
September 12, 2025Noland v. Land of the Free, L.P., No. B331918, California Court of Appeal, Second District (published)Plaintiff-appellant's lawyer Amir Mostafavi$10,000 payable to the court clerk; the lawyer to serve the opinion on his client and the clerk to serve it on the State Bar; no sanctions awarded to opposing counselCalifornia Rules of Court, rule 8.276The court found the fabricated authorities were created by AI tools counsel used to draft his briefs
July 24, 2025Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071, D. Me.The pro se defendantNo fine; the court declined the plaintiffs' requested Rule 11 monetary sanctions and its own contemplated filing restriction, and ordered a written representation with every future filing that he personally checked each citationA certification requirement under Cok v. Family Court of R.I., 985 F.2d 32 (1st Cir. 1993)He admitted using AI software to generate the filings
July 23, 2025Johnson v. Dunn, No. 2:21-cv-1701, N.D. Ala.Three Butler Snow lawyers for the defendant (Matthew B. Reeves, William J. Cranford and William R. Lunsford); the firm and two other lawyers were released without sanctionPublic reprimand, publication of the order, copies to clients, opposing counsel and judges in their other pending cases, disqualification from the case, and referral to the Alabama State Bar; no fineThe court's inherent authority (Rule 11 did not apply to the discovery motions involved)The three lawyers confirmed in writing and at a hearing that the citations were ChatGPT hallucinations
May 5, 2025Lacey v. State Farm General Insurance Co., No. 2:24-cv-05205, C.D. Cal. (order of a special master)Plaintiff's law firms Ellis George and K&L Gates; individual lawyers not separately sanctionedSupplemental briefs struck, no further discovery relief on the disputed privilege issue, and $31,100 in total compensation to the defense, jointly and severallyThe sanctions notice cited Rules 11 and 37 and the special master's inherent authority; he found conduct "tantamount to bad faith"A lawyer at one firm used AI to produce an outline; the lawyers at the other firm did not know
February 24, 2025Wadsworth v. Walmart Inc., No. 2:23-CV-118, D. Wyo.Plaintiffs' lawyers Rudwin Ayala, T. Michael Morgan and Taly Goody; the law firms were not ordered to show causeAyala: pro hac vice admission revoked, removed as counsel, $3,000; Morgan and Goody: $1,000 eachRule 11 and the court's inherent authorityThe lawyers admitted the cases were hallucinated by their firm's in-house AI platform; the court accepted that account and credited the drafting lawyer's honesty and candor
November 25, 2024Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281, E.D. Tex.Plaintiff's lawyer Brandon Monk$2,000 penalty, at least one hour of continuing legal education on generative AI, and a copy of the order to his clientRule 11(b)(2); the show-cause order also cited the district's Local RulesHe admitted using a generative AI tool and failing to verify the content
January 30, 2024Park v. Kim, No. 22-2057, Second CircuitAppellant's lawyer Jae S. LeeReferral to the court's Grievance Panel under Local Rule 46.2 and an order to give the client a copy of the decision; no fineThe court's statement of the duties Rule 11 imposes and its Local Rule 46.2She reported relying on ChatGPT and not reading the decision she cited
June 22, 2023Mata v. Avianca, Inc., No. 22-cv-1461, S.D.N.Y.Lawyers Peter LoDuca and Steven A. Schwartz and their firm, Levidow, Levidow & Oberman P.C.$5,000 jointly and severally, paid to the court, plus letters to the client and to each judge falsely named as the author of a fake opinionRule 11 and, alternatively, the court's inherent power; the court declined to sanction separately under 28 U.S.C. 1927The court found the fake opinions were created by ChatGPT, and found bad faith on the part of the individual lawyers

How many cases are there in total? There is no official national count. In Fletcher, the Fifth Circuit reported that an independent researcher's database had identified 239 cases of hallucination by lawyers in the United States as of February 18, 2026, a figure that excluded cases involving pro se litigants and judges. That is a tracker's number as the court quoted it, not a court finding.

How courts decide sanctions for fake citations

Rule 11 and its state equivalents

Most of the federal trial-court sanctions on this page rest on Federal Rule of Civil Procedure 11. Under Rule 11(b), by presenting a pleading, written motion or other paper, "an attorney or unrepresented party certifies" that, after a reasonable inquiry, "the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument" for changing it. A citation to a case that does not exist cannot support a legal contention, so most of the federal trial courts on this page treated fake citations as Rule 11 violations. The clearest exceptions were Johnson v. Dunn, where Rule 11 did not apply to the discovery motions involved, and Prescott, where the court declined Rule 11 sanctions and imposed a citation-certification order instead.

Courts sanction fake citations under Rule 11, their inherent power, appellate rules such as FRAP 46(c) and state court rules, and a court may order citation certification instead of a fine.
Most federal trial-court decisions on this page rest on Rule 11; inherent power fills gaps, and appellate and state courts use their own rules.

The Second Circuit stated the floor in Park v. Kim: "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." The Eastern District of Texas quoted that line in Gauthier when it fined a lawyer $2,000.

State courts use their own rules. The California Court of Appeal in Noland relied on California Rules of Court, rule 8.276, which lets it sanction a party who unreasonably violates the Rules of Court. The Supreme Court of Georgia in Payne relied on its inherent authority and its own Rule 7, and wrote: "While we have no rule against the responsible use of artificial intelligence software by attorneys, citing cases that do not exist or do not support the proposition for which they are cited is a violation of this Court's rules."

Inherent power, 28 U.S.C. 1927 and appellate rules

Courts also have what the Fifth Circuit called the "inherent power to impose sanctions for abuse of the judicial process." In Mata, Judge Castel sanctioned the lawyers under Rule 11 and, alternatively, under the court's inherent power, after finding "bad faith on the part of the individual Respondents based upon acts of conscious avoidance and false and misleading statements to the Court." He declined to impose a separate sanction under 28 U.S.C. 1927.

Inherent power fills gaps where a rule does not reach. Rule 11(d) says the rule "does not apply to disclosures and discovery requests, responses, objections, and motions under Rules 26 through 37." Because the fake citations in Johnson v. Dunn were in discovery motions, the court found that Rule 11 did not apply, declined to rest on the Alabama professional conduct rule and a local rule, and wrote: "This series of gaps leaves the court with only its inherent authority."

Federal appeals courts use the appellate rules. The Fifth Circuit in Fletcher relied on Federal Rule of Appellate Procedure 46(c), which covers "conduct unbecoming a member of the bar," together with its inherent power. The Sixth Circuit in Whiting used Federal Rule of Appellate Procedure 38 (frivolous appeals) and its inherent authority, and wrote that "citing even a single fake case can be sanctionable."

What courts weigh

The opinions on this page return to the same factors: whether the lawyer or litigant was candid when caught, whether they corrected the record promptly, how many citations were fake, and whether they kept going after a warning.

Candor lowers the penalty. The District of Wyoming in Wadsworth called the drafting lawyer's "honesty and candor" a mitigating fact. In Fletcher, the Fifth Circuit wrote that "had Hersh accepted responsibility and been more forthcoming, it is likely that the court would have imposed lesser sanctions."

Scale and persistence raise it. The Oregon court in Couvrette found that the plaintiffs had filed three briefs citing fifteen non-existent cases and fabricated quotations attributed to eight real authorities, called the case "a notorious outlier in both degree and volume," found that the plaintiffs shared responsibility with their lawyer, and dismissed the claims with prejudice. On June 12, 2026, the court ordered Brigandi to show cause why he should not be held in contempt for not paying the $15,500. In Lothamer, the court set the fine at $100 per false citation and warned that the amount would double for each repeat violation.

Landmark AI citation cases explained

Mata v. Avianca (S.D.N.Y., 2023)

Mata v. Avianca is the case that made the issue famous. Two lawyers and their firm filed a brief citing non-existent judicial opinions with fake quotes and citations that, the court found, were created by ChatGPT, and one of the lawyers testified that he had used ChatGPT. On June 22, 2023, Judge P. Kevin Castel imposed a $5,000 penalty jointly and severally and ordered letters to the client and to each judge falsely named as an author.

The opinion's most quoted line sets the rule courts still apply: 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."

Park v. Kim (2d Cir., 2024)

In Park v. Kim, decided January 30, 2024, the Second Circuit affirmed the dismissal of the appellant's case and then turned to her lawyer's brief, which cited a decision that did not exist. Counsel reported that she relied on ChatGPT and did not read or confirm the decision. The court imposed no fine but referred her to its Grievance Panel under Local Rule 46.2 and ordered her to give her client a copy of the decision.

Johnson v. Dunn (N.D. Ala., 2025)

Johnson v. Dunn shows that a large firm's lawyers face the same consequences. Three lawyers for the defendant confirmed that citations in discovery motions were ChatGPT hallucinations. On July 23, 2025, Judge Anna M. Manasco publicly reprimanded them, disqualified them from the case, ordered the order shared with clients, opposing counsel and judges in their other pending cases, and referred the matter to the Alabama State Bar. She imposed no fine and released the firm and two other lawyers without sanction, writing that "fabricating legal authority is serious misconduct that demands a serious sanction."

Noland v. Land of the Free (Cal. Ct. App., 2025)

Noland v. Land of the Free is a published California appellate opinion, filed September 12, 2025. The court affirmed the judgment against the plaintiff and sanctioned his lawyer $10,000 because AI tools he used to draft his briefs created fabricated authorities. The court said no California court had addressed the issue and published the opinion "as a warning."

Its central line is now widely quoted: "no brief, pleading, motion, or any other paper filed in any court should contain any citations--whether provided by generative AI or any other source--that the attorney responsible for submitting the pleading has not personally read and verified." The court declined to award sanctions to opposing counsel because they had not alerted the court to the fake citations.

Fletcher v. Experian (5th Cir., 2026)

In Fletcher v. Experian, a published opinion filed February 18, 2026, Chief Judge Elrod's panel found that the appellant's lawyer used generative AI to draft "a substantial portion--if not all--of her reply brief and failed to check the brief for accuracy." She omitted any mention of AI at first and admitted it only when asked directly. The court ordered her to pay $2,500 under FRAP 46(c) and its inherent power.

The opinion also explains that the Fifth Circuit had considered an AI certification rule and declined to adopt it, relying on existing rules instead.

Payne v. State (Ga., 2026)

Payne v. State is a sanction of a prosecutor by a state supreme court. In a murder appeal decided May 5, 2026, the Supreme Court of Georgia found that the State's briefs and the trial court's order denying a new trial, an order "largely prepared by" an assistant district attorney, cited cases that do not exist or do not support the propositions cited. The prosecutor acknowledged using AI software.

The court suspended her privilege to practice before the Supreme Court of Georgia for six months, conditioned reinstatement on 12 extra hours of continuing legal education, admonished her and the district attorney's office, and vacated the trial court's order with instructions to issue a new one without fake citations. The court said its sanctions do not affect any discipline the State Bar of Georgia may pursue.

Can pro se litigants be sanctioned for AI citations?

Yes. Rule 11 applies to an "unrepresented party" in the same words it applies to an attorney, and courts have said self-represented litigants must meet the same standard. In Prescott, the District of Maine wrote that pro se litigants "must be held generally to the same standards as an attorney."

In Lothamer Tax Resolution, Inc. v. Kimmel (W.D. Mich.), the court found on December 1, 2025 that the pro se defendant violated Rule 11 and ordered him to pay $2,900, $100 for each of 29 false citations. He denied using generative AI. The court called that denial "inadequate and not credible" but said it need not decide whether he actually used AI; the sanction rested on the false citations themselves.

In Everett J. Prescott, Inc. v. Beall (D. Me., July 24, 2025), the pro se defendant admitted using AI software that produced miscitations and fictitious citations and promised not to do it again. The court declined the plaintiffs' request for monetary sanctions under Rule 11 and decided against a filing restriction it had itself been considering. Instead it ordered him to include, with each future filing, "a written representation that he has personally checked each legal citation and each citation is accurate and stands for its asserted proposition."

If you are representing yourself, court self-help centers, legal aid programs funded by the Legal Services Corporation and state bar lawyer referral services can help you find a person to review your papers. Our page on whether AI can give legal advice covers what AI chatbots can and cannot do for you and where to find free or low-cost help.

Fake citations can cost a self-represented party even without a sanction. In September 2026 the Idaho Supreme Court affirmed a defamation judgment, declined to reach most of the appellant's issues for failing its appellate standards, and said only six of twenty-two quotations in her brief were accurate; we covered that Idaho defamation appeal with apparent AI citations separately.

Judges' own AI errors

Judges have also issued orders containing errors that were later attributed to AI. In a Southern District of Mississippi challenge to the state's anti-DEI law (on appeal as Jackson Federation of Teachers v. Fitch), Judge Henry Wingate's July 20, 2025 temporary restraining order was removed from the docket and replaced with a corrected version that, according to the Fifth Circuit, was docketed on July 22, 2025 and backdated to July 20, and an August 1, 2025 order described the errors as "clerical."

In a published opinion filed October 22, 2026, the Fifth Circuit recorded that the judge later "admitted the errors, claiming that a law clerk had used AI to assist drafting an earlier version of the TRO that was docketed by mistake." It vacated the preliminary injunction and directed that the case be reassigned to a different district judge. Our news report on the Fifth Circuit reassignment covers that opinion in detail.

In In re CorMedix Inc. Securities Litigation (D.N.J.), Judge Julien Xavier Neals issued a text order on July 23, 2025 saying a June 30, 2025 opinion and order "were entered in error" and directing that they be removed from the docket. That docket entry does not mention AI; news reports say the judge later told the Senate Judiciary Committee that a staff member had used an AI tool.

Proposed orders drafted by a party are another route for fake citations to reach a judge's signature. In Payne, the Supreme Court of Georgia wrote that it "strongly encourage[s] trial courts to carefully review proposed orders with the understanding that artificial intelligence software, with all of its potential risks and benefits, may have been used to prepare such proposed orders." How courts govern judges' own AI use is covered in our AI in court guide.

How to avoid AI citation sanctions

Open and read every case, statute and quotation you cite in an official source before you file, and confirm that it says what your filing says it does. That is the duty every decision on this page enforces, whether or not AI was involved.

Courts say the same in their guidance for self-represented filers. The U.S. District Court for the Northern District of California tells pro se filers that "regardless of which tools you use, you are responsible for everything you file with the Court" and to "confirm that any cited case exists." California's Fourth Appellate District tells filers, "You must make sure all court papers are correct, even if AI helped," and "AI is not a lawyer."

Some states now write the verification duty into their court rules. Among the states we checked, Florida (Rule 2.515(d)(2), in force since June 15, 2026) requires every signer to certify that cited authorities "exist and are accurately cited," and Connecticut (Practice Book Section 4-9, in force since June 23, 2026) requires anyone who uses generative AI in a filing to "independently verify all citations, legal authorities or evidence produced by generative AI." Indiana (amended Trial Rule 11 and new Trial Rule 11.1, in force since August 1, 2026) makes a signature certify "that any cited legal authority is authentic," and both rules expressly cover filings prepared with the assistance of artificial intelligence, by lawyers and by self-represented parties. Maryland and Texas have proposed similar citation-verification rules that are not in force. As of November 6, 2026, none of the national federal rules has an AI-specific provision, though some district courts and individual judges have their own AI orders. Our court AI rules by state page has the full state table, and our AI in court guide covers federal and local rules.

What to Watch in 2027

These are the dated and pending events in the record as of November 6, 2026. None has a confirmed 2027 date unless stated.

  • Federal Rule 11 suggestion 26-CV-21: a proposal to add a Rule 11(b)(5) under which a signer would certify that "the legal authorities exist and are accurately cited" was on the Civil Rules Advisory Committee's October 21, 2026 agenda with a staff recommendation to drop it. The committee's decision is not yet confirmed, and no further date is set.
  • Maryland Rule 1-311: the Rules Committee's 229th Report proposes that an attorney's signature certify the attorney "confirmed the existence and authenticity of each legal authority cited." Comments are due November 19, 2026; the Supreme Court of Maryland would act by a later rules order, and no date is set.
  • Texas Rule 13 and Appellate Rules 9 and 52: proposed changes making the signer verify citations received preliminary approval on June 26, 2026 (Misc. Docket No. 26-9054). We found no final approval order as of November 6, 2026, so they remain proposals with no confirmed effective date.
  • Connecticut Practice Book: the generative AI sections (4-9 and the revised 4-2(b)) took effect June 23, 2026, and the matching appellate rules on July 14, 2026; the remaining amendments in the same Superior Court package take effect January 1, 2027.
  • New sanctions decisions: courts keep issuing them. We add decisions to this tracker only after reading the order itself.

This page is general legal information about court sanctions for fake citations, verified as of November 6, 2026. It is not legal advice. For advice about a specific case, talk to a lawyer licensed in your state.

Frequently Asked Questions

Can a lawyer be sanctioned for using ChatGPT?

A lawyer can be sanctioned for filing fake citations, whether ChatGPT or any other source produced them. The court in Mata v. Avianca said using a reliable AI tool is not improper in itself, but lawyers must ensure their filings are accurate. Lawyers have been fined, ordered to pay the other side's fees, disqualified and referred to bar authorities, for example in Mata v. Avianca (S.D.N.Y., 2023) and Johnson v. Dunn (N.D. Ala., 2025).

What happened in Mata v. Avianca?

In Mata v. Avianca (S.D.N.Y.), two lawyers and their firm filed a brief citing non-existent court opinions that the court found were created by ChatGPT. On June 22, 2023, Judge P. Kevin Castel fined them $5,000 jointly under Rule 11 and, alternatively, the court's inherent power, and ordered letters to their client and to each judge falsely named as an author.

What is the largest AI citation sanction?

There is no official national list, so we can only say which is largest among the 13 decisions on this page. That is Couvrette v. Wisnovsky (D. Or.): the court ordered one lawyer to pay $15,500 to the court in December 2025 and, in March 2026, ordered him and his local co-counsel to pay the defendants $94,704.38 in fees and costs between them, after dismissing the plaintiffs' claims with prejudice.

Can pro se litigants be sanctioned for AI citations?

Yes. Federal Rule of Civil Procedure 11 applies to unrepresented parties as well as attorneys. A Michigan federal court fined a pro se defendant $2,900 on December 1, 2025 for 29 false citations without finding he used AI, and a Maine federal court on July 24, 2025 ordered a pro se defendant who admitted AI use to certify every citation in future filings.

Is using AI in a court filing illegal?

No court rule or decision discussed on this page makes it illegal. What courts sanction is filing citations or quotations that are fake or wrong. Some courts and judges have their own AI rules, and among the states we checked, Florida and Indiana require every signer to confirm that cited authorities exist or are authentic, and Connecticut requires anyone who uses generative AI in a filing to verify the citations it produced, so check the rules of your court and the judge assigned to your case.

Have judges made AI errors?

Yes, according to the record. In an October 22, 2026 opinion, the Fifth Circuit recorded that a Mississippi federal judge admitted a law clerk had used AI to help draft an earlier version of a July 2025 restraining order that contained errors. A New Jersey federal judge removed a June 2025 opinion as entered in error; that docket entry does not mention AI, though news reports say the judge told the Senate Judiciary Committee a staff member used an AI tool.

Updates

Independently fact-checked against the cited primary sources; governing law re-checked for recent changes

Sources and References

  1. Couvrette v. Wisnovsky, No. 1:21-cv-00157 (D. Or.), Opinion and Order on Sanctions, ECF 215 (Dec. 12, 2025)(storage.courtlistener.com)
  2. Couvrette v. Wisnovsky, No. 1:21-cv-00157 (D. Or.), Opinion and Order on fees and apportionment, ECF 225 (Mar. 23, 2026)(storage.courtlistener.com)
  3. Couvrette v. Wisnovsky, No. 1:21-cv-00157 (D. Or.), Order to Show Cause, ECF 232 (June 12, 2026)(storage.courtlistener.com)
  4. Mata v. Avianca, Inc., No. 22-cv-1461 (S.D.N.Y.), Opinion and Order on Sanctions, ECF 54 (June 22, 2023)(storage.courtlistener.com)
  5. Federal Rules of Civil Procedure (Dec. 1, 2024), Rule 11(www.uscourts.gov).gov
  6. Johnson v. Dunn, No. 2:21-cv-1701 (N.D. Ala.), Sanctions Order, Doc. 204 (July 23, 2025)(storage.courtlistener.com)
  7. Lothamer Tax Resolution, Inc. v. Kimmel, No. 1:25-cv-00579 (W.D. Mich.), Order, ECF 184 (Dec. 1, 2025)(storage.courtlistener.com)
  8. Everett J. Prescott, Inc. v. Beall, No. 1:25-cv-00071 (D. Me.), Order on Motion for Sanctions, ECF 140 (July 24, 2025)(storage.courtlistener.com)
  9. Fletcher v. Experian Information Solutions, Inc., No. 25-20086 (5th Cir. Feb. 18, 2026)(www.ca5.uscourts.gov).gov
  10. Payne v. State, No. S26A0459 (Ga. May 5, 2026)(www.gasupreme.us).gov
  11. Whiting v. City of Athens, Nos. 24-5918/5919/25-5424 (6th Cir. Mar. 13, 2026)(storage.courtlistener.com)
  12. Noland v. Land of the Free, L.P., No. B331918 (Cal. Ct. App. Sept. 12, 2025)(courts.ca.gov).gov
  13. Lacey v. State Farm General Insurance Co., No. 2:24-cv-05205 (C.D. Cal.), Order of Special Master, Doc. 119 (May 5, 2025)(storage.courtlistener.com)
  14. Wadsworth v. Walmart Inc., No. 2:23-CV-118 (D. Wyo.), Order on Sanctions, ECF 181 (Feb. 24, 2025)(storage.courtlistener.com)
  15. Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281 (E.D. Tex.), Memorandum and Order, ECF 48 (Nov. 25, 2024)(storage.courtlistener.com)
  16. Gauthier v. Goodyear Tire & Rubber Co., No. 1:23-CV-281 (E.D. Tex.), Order to Show Cause, ECF 44 (Nov. 7, 2024)(storage.courtlistener.com)
  17. Park v. Kim, No. 22-2057 (2d Cir. Jan. 30, 2024)(storage.courtlistener.com)
  18. Jackson Federation of Teachers v. Fitch, No. 25-60496 (5th Cir. Oct. 22, 2026)(www.ca5.uscourts.gov).gov
  19. S.D. Miss. No. 3:25-cv-00417, Order of Aug. 1, 2025 (ECF 65)(storage.courtlistener.com)
  20. In re CorMedix Inc. Securities Litigation (D.N.J.), docket, text order ECF 126 (July 23, 2025)(www.courtlistener.com)
  21. U.S. District Court for the Northern District of California, Using AI Tools in Your Case(cand.uscourts.gov).gov
  22. California Court of Appeal, Fourth Appellate District, Using AI for Your Court Case? Read This First (Oct. 31, 2025)(appellate.courts.ca.gov).gov
  23. In re Amendments to Florida Rule of General Practice and Judicial Administration 2.515, No. SC2026-0673 (Fla. May 28, 2026)(flcourts-media.flcourts.gov).gov
  24. Connecticut Law Journal (June 23, 2026), Practice Book amendments including new Section 4-9 and revised Section 4-2(www.jud.ct.gov).gov
  25. Connecticut Law Journal (July 14, 2026), amendments to Rules of Appellate Procedure Sections 60-4, 62-6 and 85-2(www.jud.ct.gov).gov
  26. Advisory Committee on Civil Rules, agenda book for October 21, 2026 meeting (suggestion 26-CV-21)(www.uscourts.gov).gov
  27. Suggestion 26-CV-21, proposed Fed. R. Civ. P. 11(b)(5)(www.uscourts.gov).gov
  28. Maryland Standing Committee on Rules of Practice and Procedure, 229th Report(www.mdcourts.gov).gov
  29. Supreme Court of Texas, Misc. Docket No. 26-9054, Preliminary Approval of Amendments to Tex. R. Civ. P. 13 and Tex. R. App. P. 9 and 52 (June 26, 2026)(www.txcourts.gov).gov
  30. Supreme Court of Texas, 2026 administrative orders(www.txcourts.gov).gov
  31. Indiana Supreme Court, Order Amending Rules of Trial Procedure, Cause No. 26S-MS-8 (July 14, 2026; effective Aug. 1, 2026)(www.in.gov).gov
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