We recently received an email from a long-time reader calling our attention to a litigant’s bizarre artificial-intelligence-aided shenanigans in Conlan Tire Co., LLC v. Gonzales, 2026 WL 676450 (E.D. Mich. March 10, 2026).  This wasn’t your run-of-the-mill AI-generated citations situation, but rather a use of ChatGPT that provided revealing insights into the litigant’s sanctionable intentions.  The litigant in Conlan Tire wasn’t a personal injury plaintiff trying to eliminate adverse evidence – he was a defendant in an unfair competition lawsuit – but he just as well could have been.

In Conlan, our devious litigant denied signing a critical agreement with the plaintiff, his erstwhile employer, and claimed that an image of his signature lifted from something else had been perfidiously added to the agreement.  But digital forensic examination his cellphone exposed an interesting conversation with ChatGPT:

[T]he digital forensic examiners discovered that [the litigant] had used ChatGPT to research how and when deleted emails could be retrieved and produced by Yahoo under a subpoena.  ChatGPT provided the following responses to [the litigant’s] pointed queries:  Yahoo could not retrieve an email deleted from his account a year ago, even under a subpoena; an email permanently deleted today would be retrievable by Yahoo for at most seven days, and Yahoo does not maintain individual deletion histories nor does it track deleted emails in an audit log.  [The litigant] provided the forensic examiner access to his Yahoo account 28 days after he conducted his ChatGPT research on deleted Yahoo emails.

2026 WL 676450, at *2 (citations and footnote omitted).  See also Conlan Tire Co., LLC v. Gonzales, 2025 WL 4704197, at *2 (E.D. Mich. Aug. 11, 2025) (discussing the same facts in greater detail). 

This litigant’s use of ChatGPT supported Conlan’s grant of spoliation sanctions and rejection of the litigant’s “contrived, implausible, and deceptive arguments that his ChatGPT queries were not indicative of his intent to delete emails.”  Id. at *3.  The adverse inferences in large part led the court to grant the plaintiff’s requested injunction against the defendant.  2025 WL 4704197, at *5.

This is not the first time the Blog has chronicled litigants (or their lawyers) using artificial intelligence to do stupid things.  We’ve discussed litigants using AI to do their own legal research unbeknownst even to their lawyers.  And like many others, we’ve bewailed the plague of “hallucinated” AI-generated fake citations in legal papers and even expert reports.

As a result, we’ve decided to review every judicial decision that mentions “ChatGPT” (well over 500 decisions) and see how that system – the first and foremost generally available generative AI large language model – has been used and misused in actual litigation.  We’re not trying to pick on ChatGPT.  Other LLMs share these risks.  However, ChatGPT is both the longest existing such platform, and often cited as the prime example of this type of AI (we found lots of “such as ChatGPT” references that we are not including here).  Another reason for focusing on ChatGPT is that it was not designed for legal work and “is generally understood to be the most problematic AI platform to use for drafting legal filings.”  In re Hines, 2025 WL 3137723, at *7 (Bankr. S.D. Ohio Nov. 7, 2025).

The majority of the decisions that mention ChatGPT substantively (others reference it in facts not having legal significance, and still others involve suits directly against ChatGPT’s owners) involve judicial orders of two types:  either (1) orders requiring litigants to disclose use of AI generally, with ChatGPT being one of list of named AI sites; or (2) orders forbidding litigants from submitting confidential discovery materials to AI sites that are not totally closed-source or proprietary to recipient counsel, again with ChatGPT again being one of a list.  We’re not including those decisions, but they’re out there in abundance if anybody needs them. We’re not including those decisions, but they’re out there in abundance if anybody needs them.  One recent decision, however, refused to modify an existing protective order to allow a pro se plaintiff to upload confidential information into ChatGPT:

Plaintiff believes the Court should permit him to use ChatGPT to review confidential evidence because he is pro se and does not have support. . . .  Defendant argues that, aside from being unnecessary, there is substantial risk in using a public large-language model platform to process confidential information. Defendant represents that uploading confidential evidence to ChatGPT risks disclosure of [what] . . . Plaintiff acknowledges to be “sensitive information.”

The Court finds that the balance of conflicting interests weighs in favor of Defendant’s position.  It is not disputed that exposing confidential information to ChatGPT creates at least some risks with respect to how that information will be used and safeguarded.

Baqleh v. Altamirano, 2026 WL 3257576, at *2 (N.D. Cal. Oct. 28, 2026) (citations omitted).

Only a minority of the decisions mentioning ChatGPT are of the same sort of interest as Conlon.  But because they are the most relevant, both to us and to our readers, we’re starting with them.  Some of the cases involving ChatGPT concern discovery, which we expect will be a recurring issue going forward.  In Villanueva v. Las Vegas Metropolitan Police Dept., 2026 WL 2942348, at *2 (D. Nev. Sept. 29, 2026), the court ordered production of a plaintiff’s expert’s ChatGPT reliance after plaintiff failed to disclose the expert’s AI use prior to the expert’s deposition.  Id. at *3. However, the expert’s “questions and prompts to ChatGPT” were protected work product. Id. at *3-4.  Further, the expert’s “creation of a draft report on ChatGPT is protected as a draft report, because . . . some of this information was directly incorporated into [the expert’s] own written report.”  Id. at *4. 

Concord Music Group, Inc. v. Anthropic PBC, 2025 WL 1482734 (N.D. Cal. May 23, 2025), held that “Chat GPT prompts” run by lawyers during “pre-suit investigation” were protected work product.  Id. at *2 (“failed prompts and related settings are attorney work product”).  Concord Music followed Tremblay v. OpenAI, Inc., 2024 WL 3748003 (N.D. Cal. Aug. 8, 2024), which likewise held that certain “ChatGPT prompts were queries crafted by counsel and contain counsel’s mental impressions and opinions about how to interrogate ChatGPT” about issues relevant to the litigation.  Id. at *2 (citation omitted).

In Jones v. Delta Air Lines, Inc., 2026 WL 1091186, at *4-5 (E.D. Mich. April 22, 2026), a pro se plaintiff’s attorney/client privilege claim that ChatGPT was acting as her attorney was rejected, and plaintiff was directed to answer questions about her use of the service.  Accord, Lucas v. Scharf, 2026 WL 642917, at *2 n.2 (W.D.N.C. Feb. 25, 2026) (“‘conversations’ with AI tools such as ChatGPT are not privileged and may be subject to discovery”).  On the other hand, Warner v. Gilbarco, Inc., 820 F. Supp.3d 629, 636-37 (E.D. Mich. 2026), held that “ChatGPT (and other generative AI programs) are tools, not persons, even if they may have administrators somewhere in the background,” and thus a pro se plaintiff’s interactions with the program received work product protection.

Even more seriously, Flexport, Inc. v. Freightmate AI, Inc., 2026 WL 2771671 (N.D. Cal. Sept. 17, 2026), imposed spoliation sanctions under Fed. R. Civ. P. 37(e) for a litigant’s destruction of several files containing “prompts used with ChatGPT.”  Id. at *8 (ordering “for the jury to be instructed on the law on suppression of evidence” to “determine whether or not to consider the lost ESI would have been unfavorable to Defendants”).

As we have discussed previously, another group of cases has excluded expert witnesses because the presence of ChatGPT-generated hallucinations in their reports “shattered” their “credibility.”  Ledoux v. Outliers, Inc., 2026 WL 2408808, at *7 (W.D. Wash. Aug. 18, 2026); Kohls v. Ellison, ___ F. Supp.3d ___, 2025 WL 66514, at *4 (D. Minn. Jan. 10, 2025).  Recently, an unpublished (and thus not citable in the state) California state appellate decision decided with respect to ChatGPT generated expert opinions:

We agree with [petitioner] in principle that the use of AI by a forensic psychologist to generate an expert opinion, at present, would constitute a novel scientific technique.  Any such opinion, therefore, would be inadmissible absent an adequate foundation demonstrating the reliability of the psychologist’s methodology, including the general acceptance of the new technique in the relevant scientific community.

Gillespie v. Superior Court, 2026 WL 3333170, at *8 (Cal. App. Nov. 4, 2026) (citations and quotation marks omitted).

Other forms of ChatGPT-generated “evidence” have also been excluded.  Buehler v. Nationstar Mortage [sic] LLC, 2026 WL 2349853, at *2 (W.D. Wash. Aug. 13, 2026), excluded Chat GPR-generated “calculations” where the proffer included “no explanation as to what information was given to ChatGPT, who provided such information, or under what circumstances the Rules of Evidence would allow the Court to accept ‘simple calculations’ from ChatGPT to evaluate the merits of [plaintiff’s] claim.”  Lepp v. Mallett, 2026 WL 125968, at *6 (E.D. Mich. Jan. 16, 2026), refused to consider a pro se plaintiff’s ChatGPT-generated “legal analysis report” as improper (“the place for legal arguments is in the brief, not the exhibits”) and unreliable since ChatGPT “do[es] not − and cannot − decide what is true and what is false.”  See also Veleber v. Alphabet, Inc., 2026 WL 2475778, at *1-2 (N.D. Cal. Aug. 24, 2026) (holding that plaintiff’s “purported ‘declarations’ or ‘statements’ from AI systems” (including ChatGPT) were “fanciful allegations” and dismissing case); Wilson v. KIPP Texas, Inc., 2025 WL 3030444, at *1, 3 (N.D. Tex. Oct. 29, 2025) (sanctioning counsel for submitting as evidence “11 non-existent statements” generated by ChatGPT); United States v. Sullivan, 2025 WL 2402894, at*1 (D. Haw. Aug. 19, 2025) (ChatGPT-generated “data . . . was inaccurate and misleading, rendering the same useless for any purpose”); Pop Top Corp. v. Rakuten Kobo, Inc., 2025 WL 2098597, at *4 (N.D. Cal. July 25, 2025) (bankruptcy debtor’s “proffered ChatGPT analysis [of his deposition] lacks any independent corroboration and thus is not reliable”).  But see Ferlito v. Harbor Freight Tools USA, Inc., 2025 WL 1181699, at *4 (E.D.N.Y. April 23, 2025) (accepting expert’s testimony that he was “quite amazed” that his allegedly subsequent “ChatGPT search confirmed what he had already opined” and finding “no indication” what the expert had relied on “ChatGPT to generate a report with false authority or that his use of AI would render his testimony less reliable”).

Relevant to the consideration of a possible Fed. R. Evid. 707, the use of ChatGPT-generated information as evidence, without supporting expert explication, has been rejected.  In Pegnatori v. Pure Sports Technologies LLC, 2023 WL 6626159 (D.S.C. Oct. 11, 2023), a patent case, the court refused to credit a ChatGPT query as to “the definition of” a disputed technical term (“foam”).  Id. at *5.  “[T]he court would be taking its eye off the ball if it applied the ChatGPT definition in its review of extrinsic evidence.”  Id. at *6 (citation omitted).

Several cases, all involving the same law firm, have repeatedly refused to consider ChatGPT generated information purporting to opine on the reasonableness of fee demands.  Reliance on AI, with no accompanying expert evidence, has universally been rejected in this context.

[I]nvocation of ChatGPT as support for its aggressive fee bid is utterly and unusually unpersuasive.  As the firm should have appreciated, treating ChatGPT’s conclusions as a useful gauge of the reasonable billing rate for the work of a lawyer with a particular background carrying out a bespoke assignment for a client in a niche practice area was misbegotten at the jump. . . .  In claiming here that ChatGPT supports the fee award it urges, the [firm] does not identify the inputs on which ChatGPT relied.  It does not reveal whether any of these were similarly imaginary.  It does not reveal whether ChatGPT anywhere considered a very real and relevant data point:  the uniform bloc of precedent, canvassed below, in which courts in this District and Circuit have rejected as excessive the [firm’s] billing rates. . . .  The Court therefore rejects out of hand ChatGPT’s conclusions as to the appropriate billing rates here.  Barring a paradigm shift in the reliability of this tool, the [firm] is well advised to excise references to ChatGPT from future fee applications.

J.G. v. New York City Dept. of Education, 719 F. Supp.3d 293, 30-08 (S.D.N.Y. 2024) (citations omitted).  Unfortunately, that firm did not take that advice, and continued submitting such “evidence”:

Additional sources provided by [the firm] are also unpersuasive, and I do not recommend placing substantial weight on any of them.  Specifically, [it]references the artificial intelligence tool “ChatGPT.”  [It] relies on ChatGPT’s feedback to demonstrate what a client’s search may provide when attempting to determine hourly rates for IDEA litigation.  Here, [this] reliance on ChatGPT is inappropriate, because ChatGPT has been shown to be an unreliable resource.

D.S. v. New York City Dept. of Education, 2024 WL 2159785, at *6 (Mag. S.D.N.Y. April 29, 2024) (citations omitted), adopted, 2024 WL 2158583 (S.D.N.Y. May 14, 2024).  See also S.M. v. New York City Dept. of Education, 2025 WL 4050877, at *10 (Mag. S.D.N.Y. Nov. 10, 2025) (same as J.G.), adopted, 2026 WL 104183 (S.D.N.Y. Jan. 14, 2026); K.K. v. New York City Dept. of Education, 2024 WL 4203783, at *6 n.11 (S.D.N.Y. Aug. 22, 2024) (“invocation of ChatGPT as support for [an] aggressive fee bid is utterly and unusually unpersuasive”), adopted, 2024 WL 4203251 (S.D.N.Y. Sept. 16, 2024); S.C. v. New York City Dept. of Education, 2024 WL 3518522, at *3 (S.D.N.Y. July 24, 2024) (“reject[ing] results from ChatGPT-4 as nonprobative and unreliable” on fee calculations); Z.H. v. New York City Dept. of Education, 2024 WL 3385690, at *5 (S.D.N.Y. July 12, 2024) (same as J.G.); R.R. v. New York City Dept. of Education, 2024 WL 6046877, at *6 (Mag. S.D.N.Y. June 3, 2024) (same as D.S.), adopted, 2025 WL 3516102 (S.D.N.Y. Dec. 8, 2025); M.B. v. New York City Dept. of Education, 2024 WL 1435330, at *4 (Mag. S.D.N.Y. Jan. 24, 2024) (“declin[ing] to consider ChatGPT’s claims” since it is “notorious for inventing false information”), adopted, 2024 WL 1343596 (S.D.N.Y. March 30, 2024).

Nor can “conversation with ChatGPT” be considered as “newly discovered evidence.”  United States v. Chin, 2024 WL 251496, at *1 (D.C. Cir. Jan. 23, 2024).  United States v. Jones, 2026 WL 615699 (S.D. Ohio March 5, 2026), held that a losing party cannot create newly discovered evidence belatedly “from a question put to Chat GPT.”  “While the chatbot is not licensed to practice law and it was careful to distinguish what it reported from legal advice, its output cannot be properly classified as making Defendant’s claim newly ripe.”  Id. at *2.  Accord United States v. Bauer, 2025 WL 2084917, at *3 (N.D. Cal. July 24, 2025) (same result).

If you think that AI has created a license for lazy lawyers and lazier litigants to run amok, you would be right.  The bulk of Chat-GPT-related decisions that that we found concern case-specific (ab)use of ChatGPT (similarly to what can happen with other AI) involve its propensity to generate hallucinated citations, quotations, etc., in legal papers.  We start with the appellate caselaw.  “The use of AI is now so pervasive in legal practice that attorneys can no longer credibly claim ignorance of its pitfalls, including its propensity to hallucinate legal authority.”  Douglas v. Deutsche Bank National Trust Co., 363 A.3d 1088 (D.C. 2026).  “[T]he use of artificial intelligence must be accompanied by the application of actual intelligence in its execution.”  Id. at 1091 (citation and quotation marks omitted). 

Today we join the chorus reminding attorneys while generative AI may be a useful tool, it is no substitute for human intellect and professional judgment.  The duty to verify the law before presenting it to a court is woven into the profession itself, and while technology may evolve at breathtaking speed, the ethical obligations of lawyers cannot bend to the speed of progress.  A lawyer’s duties cannot be delegated to a machine capable of confidently inventing what it cannot legitimately find.

Southland Homes & Real Estate & Investment, LLC v. Lam, 348 Cal. Rptr.3d 473, 475 (Cal. App. 2026) (sanctioning ChatGPT-generated citations in appellate briefing).  See Perez-Castillo v. Blanche, 177 F.4th 837, 845-46 (7th Cir. 2026) (attorney sanctioned for claiming that “ChatGPT ‘hallucinate[d] facts not present in the record in this matter and insert[ed] them into the draft petition” and that it made her “correct case citations incorrect”); Park v. Kim, 91 F.4th 610, 615 (2d Cir. 2024) (arguments based on “non-existent precedent generated by ChatGPT” are an “abuse of the adversary system”) (citation and quotation marks omitted); Tov Realty, LLC v. Suarez, 360 A.3d 1062, 1066 (Conn. 2026) (attorney claiming that ChatGPT surreptitiously added hallucinated citations to a properly prepared appellate brief sanctioned); State v. Sandoval, 2026 WL 2661673, at *1-2 (N.M. Sept. 9, 2026) (attorney held in “direct contempt” and barred from any future appearances for submitting ChatGPT-generated “factual and legal misrepresentations,” including “wholly fabricated witnesses”); State ex rel. Oklahoma Bar Ass’n v. Reeves, ___ P.3d ___, 2026 WL 1480563, at *2 (Okla. May 27, 2026) (attorney publicly reprimanded for repeatedly submitting papers with hallucinated ChatGPT citations that “were completely made up”); Ex parte Thomas, ___ S.W.3d ___, 2026 WL 2880076, at *8 (Tex. App. Sept. 24, 2026) (dismissing appeal as inadequately briefed due to multiple ChatGPT hallucinated citations); Scott v. Illinois Human Rights Commission, ___ N.E.3d ___, 2026 WL 2167461, at *6-8 (Ill. App. July 28, 2026) (attorney sanctioned; after filing two ChatGPT generated briefs, the second a response to the court’s order regarding hallucinations in the first brief; “no matter how much one pays for ‘premier’ or ‘corporate’ versions of AI products, it does not negate an attorney’s obligation to verify all citations of authority”); State v. Coleman, 280 N.E.3d 1042, 1072 (Ohio App. 2026) (attorney who repeatedly filed ChatGPT hallucinated papers held in contempt, disqualified, fined, and more), appeal allowed, 282 N.E.3d 834 (Ohio 2026); Matter of Zareh, 250 N.Y.S.3d 534, 538 (N.Y.A.D. 2026) (attorney publicly censured for ChatGPT hallucinations); Mezu v. Mezu, 346 A.3d 181, 188, 190 193 (Md. App. 2025) (referring counsel for discipline for including ChatGPT “citation irregularities” in appellate briefing; “[a] competent attorney reads the legal authority cited in court pleadings”); In re Kenney, 422 So.3d 905, 927 (La. App. 2025) (sanctions affirmed against ChatGPT-reliant attorney who cited “fabricated” cases); Noland v. Land of the Free, L.P., 336 Cal. Rptr.3d 897, 913-14 (Cal. App. 2025) (pervasive hallucinations in ChatGPT-using lawyer’s brief justified declaring the appeal “frivolous”); Garner v. Kadince, Inc., 571 P.3d 812, 815 (Utah App. 2025) (“every attorney has an ongoing duty to review and ensure the accuracy of their court filings” and counsel here “fell short of their gatekeeping responsibilities . . . when they submitted a petition that contained fake precedent generated by ChatGPT”; monetary sanctions imposed).

The most frequently cited trial court decision addressing hallucinated ChatGPT material in attorney-filed legal papers is Mata v. Avianca, Inc., 678 F. Supp.3d 443 (S.D.N.Y. 2023), in which an attorney “submitted non-existent judicial opinions with fake quotes and citations created by the tool ChatGPT, then continued to stand by the fake opinions after judicial orders called their existence into question.”  Id. at 448.

Many harms flow from the submission of fake opinions.  The opposing party wastes time and money in exposing the deception.  The Court’s time is taken from other important endeavors.  The client may be deprived of arguments based on authentic judicial precedents.  There is potential harm to the reputation of judges and courts whose names are falsely invoked as authors of the bogus opinions and to the reputation of a party attributed with fictional conduct.  It promotes cynicism about the legal profession and the American judicial system.

Id. at 448 (footnote omitted).  Thus, Mata held that “[a]n attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.”  Id. at 461 (citation omitted).  Both the offending lawyer and his law firm were sanctioned under Rule 11 and the court’s inherent powers upon the court finding subjective bad faith.  Id. at 464-65.

Other trial court opinions addressing ChatGPT-generated hallucinations are: Miller v. Regions Bank, 833 F. Supp.3d 1201, 1213, 1215, 1218-19, 1221 (N.D. Ala. 2026) (attorney held in civil contempt and suspended from practicing before the court for filing a brief with numerous ChatGPT-generated hallucinations, “obfuscating” his use, and then deleting his account after being ordered to produce it to the court); Rivera v. Triad Properties Corp., 829 F. Supp.3d 983, 1029 (N.D. Ala. 2026) (disqualification, monetary, and other sanctions imposed on an attorney who “pair[ed] his [ChatGPT] misuse with a refusal to accept responsibility and further false statements to the court”); State National Insurance Co., Inc. v. Treadwell, 826 F. Supp.3d 1352, 1357 (N.D. Ala. 2026) (attorney publicly reprimanded for submitting legal papers containing ChatGPT hallucinated citations); Barkley v. City of Tempe, 2026 WL 3015647, at *4 (D. Ariz. Oct. 7, 2026) (parties filing “paper[s] incorporating inaccurate or undeclared generative AI outputs, including but not limited to inaccurate or non-existent case citations” subject to sanctions “without further warning”); Tiekert v. Village of Mamaroneck, 2026 WL 2690037, at *6-8 (S.D.N.Y. Sept. 14, 2026) (attorney held in bad faith and sanctioned for using ChatGPT generated material “only the most superficial level of checks”; attorney used ChatGPT “without verification of its output” despite awareness of “the risk of hallucination”); Beus Gilbert PLLC v. Brigham Young University, 2026 WL 2654907, at *1 (D. Utah Sept. 9, 2026) (monetary and other sanctions imposed on lawyers who submitted ChatGPT-generated hallucinations in their briefing); Ruiz v. Magellan Financial & Insurance Services, 2026 WL 2469948, at *2-3 (D. Ariz. Aug. 24, 2026) (given “the presence of three aggravating factors (prior discipline, a pattern of misconduct/multiple offenses, and substantial experience),” lawyer received formal public reprimand for repeated submission of papers with ChatGPT-generated hallucinations); DeFord v. Koutoulas, 2026 WL 2569638, at *9 (M.D. Fla. Aug. 4, 2026 (ChatGPT using counsel and client suffered default as a sanction for, inter alia “submit[ing] fabricated authority across at least eight separate filings”); Smith v. Verra Mobility Corp., 2026 WL 1197241, at *1 (M.D. Fla. May 1, 2026) (attorney sanctioned for “negligently failing to verify multiple authorities cited [by ChatGPT and other tools] in his motion”); Gentry v. Thompson, 2026 WL 787563, at *2 (E.D. La. March 20, 2026) (“Using ChatGPT and failing to check the case citations it provides constitute not only a lapse in professional judgment, but also a violation of [Rule 11]”; sanctions imposed); Kattom v. Bondi, 2026 WL 637419, at *1-2 (W.D. La. March 6, 2026) (attorney fined for ChatGPT hallucinated citations); Allah-El v. Columbia University, 2026 WL 412646, at *1, 3-4 (S.D.N.Y. Feb. 13, 2026) (attorney who abused ChatGPT denied pro hac vice admission); Lexos Media IP, LLC v. Overstock.com, Inc., 2026 WL 265581, at *15-17 (D. Kan. Feb. 2, 2026) (attorney directly responsible ChatGPT-generated hallucinations fined $5000 and had pro hac vice revoked; other attorneys received lesser sanctions); Mattox v. Product Innovations Research, LLC, 807 F. Supp.3d 1341, 1347-48, 1350-52 (E.D. Okla. 2025) (multiple counsel sanctioned for submitting eleven pleadings with ChatGPT-hallucinated citations; “The volume and repetition of these errors show not inadvertence but systemic neglect.”; all implicated pleadings stricken); United States v. McGee, 806 F. Supp.3d 1264, 1274-75 (S.D. Ala. 2025) (“insertion of bogus citations is not a mere typographical error, nor the subject of reasonable debate. It is just wrong.”; publicly funded criminal defense lawyer must reimburse the fund, among other sanctions); ByoPlanet International, LLC v. Johansson, 792 F. Supp.3d 1341, 1351 (S.D. Fla. 2025) (multiple filings with ChatGPT-generated hallucinations “constitutes repeated, abusive, bad-faith conduct that cannot be recognized as legitimate legal practice and must be deterred”); Johnson v. Dunn, 792 F. Supp.3d 1241, 1266-67 (N.D. Ala. 2025) (law firm partners with “access to gold-standard legal research databases” who nonetheless filed documents with ChatGPT generated hallucinations were publicly reprimanded, disqualified, and referred to disciplinary authorities); N.Z. v. Fenix International Ltd., 2025 WL 3626155, at *2, 4-5 (C.D. Cal. Dec. 12, 2025) (mass tort lawyers and their local counsel “fail[ed] to verify the validity” of ChatGPT-generated material; monetary sanctions and sending copy of order to “each plaintiff” imposed); Hill v. Oklahoma County Criminal Justice Authority, 2025 WL 4036934, at *3-4 (Mag. W.D. Okla. Sept. 5, 2025) (filing of multiple briefs with ChatGPT hallucinations resulted in monetary and non-monetary sanctions), adopted, 2025 WL 3490507, at *2 (W.D. Okla. Dec. 4, 2025); Coronavirus Reporter Corp. v. Apple, Inc., 2025 WL 2162947, at *5-6 (N.D. Cal. July 30, 2025) (payment of counsel fees imposed as a sanction against attorneys who “used ChatGPT to generate in its entirety an exhibit” that they submitted on three separate occasions); Nextpulse, LLC v. Life Fitness, LLC, 2025 WL 2453720, at *3-4 (N.D. Ill. Mar. 7, 2025) (submission of “fraudulent case law” generated by ChatGPT, followed by “general lack of candor” by the attorney resulted in monetary sanctions and referral to disciplinary board); Bunce v. Visual Technology Innovations, Inc., 2025 WL 662398, at *3 (E.D. Pa. Feb. 27, 2025) (sanctioned counsel had “blindly trusted an algorithm he had never used before” and “conducted no research into ChatGPT’s efficacy as a legal tool”); Iovino v. Michael Stapleton Associates, Ltd., 2024 WL 3520170, at *7 (W.D. Va. July 24, 2024) (sanctions order to show cause where hallucinated case law was “the result of ChatGPT run amok”) (citation and quotation marks omitted); Pegnatori v. Pure Sports Technologies, LLC, 2023 WL 6626159, at *5 (D.S.C. Oct. 11, 2023) (“thus far ChatGPT’s batting average in legal briefs leaves something to be desired”; “attorneys have faced admonishments and sanctions from courts in which they made these improper and filings.”); In re Martin, 670 B.R. 636, 649 (Bankr. N.D. Ill. 2025) (counsel’s “alleged lack of knowledge of ChatGPT’s shortcomings leads me to do what courts have been doing with increasing frequency: announce loudly and clearly (so that everyone hears and understands) that lawyers blindly relying on generative AI and citing fake cases . . . will be sanctioned”); People v. Crabill, 2023 WL 8111898, at *1 (Colo. O.P.D.J. Nov. 22, 2023) (public reprimand of attorney for ChatGPT-generated hallucinations “falsely attributed . . . to a legal intern”). Cf. Walters v. Openai, L.L.C., 2025 WL 2979163, at *8-9 (Ga. Super. May 19, 2025) (summary judgment granted in defamation action because ChatGPT’s false answers to prompts could not have been made with “actual malice”; the program’s proclivity to hallucinate was both well-known and warned about).  Contra Dodge v. FirstService Residential Arizona LLC, 2025 WL 3653164, at *3 (D. Ariz. Dec. 17, 2025) (“public humiliation . . . is a sufficient remedy” for solo practitioner’s Chat-GPT hallucinations, since he lost the case anyway); Perez v. Evans, 2025 WL 2726792, at *4 (S.D.N.Y. Sept. 25, 2025) (“declining] to impose sanctions on Plaintiff for his violation of Rule 11(b), in part due to Plaintiff’s admission to using ChatGPT”)

Finally, another all-too-common use of ChatGPT is by pro se litigants, who also fail to check the validity of the output, but with arguably more of an ignorance-based excuse.  See Amarsingh v. Frontier Airlines, Inc., 2026 WL 352016, at *7 (10th Cir. Feb. 9, 2026) (pro se appeal held “frivolous as argued” due to reliance on several ChatGPT hallucinated citations); Johnson v. Johnson, 2025 WL 3034722, at *3 n.4 (Ind. App. Oct. 30, 2025) (in table at 270 N.E.3d 542) (criticizing pro se parties on both sides for submission of ChatGPT-generated hallucinations that “severely hindered” appellate review); Woodard v. Southern Trust Insurance Co., 2026 WL 3078487, at *2 (M.D. Ga. Oct. 14, 2026) (requiring signed statements by pro se litigants disclosing any AI use and swearing to the accuracy of “all facts and legal authorities”); George v. Rollins, 2026 WL 3015346, at *1 (D. Ariz. Oct. 7, 2026) (dismissing AI generated pro se complaint as not a “short and plain” statement, and prohibiting plaintiff from using AI to file an amended complaint); Garcia v. City of Monte Vista, 2026 WL 2921068, at *2 (D. Colo. Sept. 29, 2026) (attorney who filed document with false citations with a certification requirement regarding AI usage for all future filings); Butler v. The Travelers Indemnity Co., 2026 WL 3059644, at *5-6 (Conn. Super. Oct. 7, 2026) (striking pro se pleadings containing fake citations and quotations); Johnson v. Nationstar Mortgage LLC, 2026 WL 2516390, at *17-18 (D. Md. Aug. 26, 2026) (dismissing claims of pro se plaintiff who persisted in submitting papers with ChatGPT-generated hallucinated citations despite the court’s “admonition”); Booker v. U.S. Bank National Ass’n, ___ F. Supp.3d ___, 2026 WL 2254689, at *5 (D. Conn. Aug. 5, 2026) (pro se plaintiff sanctioned for ChatGPT hallucinations after “acknowledg[ing] that he had only ‘briefly read’ some of the cited cases, had not read others, and ultimately could not say whether he had read any of them before filing”); Barteca Holdings LLC v. Tacobarn Newtown LLC, ___ F. Supp.3d ___, 2026 WL 2253785, at *7 (D. Conn. Aug. 4, 2026) (attorney sanctioned for ChatGPT use resulting in “submission of unverified AI-generated legal authorities”); McQueen v. Federal National Mortgage Ass’n, 2026 WL 2210113, at *6 (C.D. Cal. July 24, 2026) (ChatGPT-generated pro se complaint dismissed; it “contains circuitous factual assertions, legal commentary, confounding headers, . . . other unnecessary information that renders each paragraph difficult to understand if not incomprehensible,” and “baseless legal analysis and conclusions of law”); Peters v. Banner Health, 2026 WL 143152, at *4-6 (Mag. S.D. Tex. Jan. 15, 2026) (pro se plaintiff’s repeated filings rife with ChatGPT-generated hallucinations was contumacious and warranted dismissal with prejudice), adopted, 2026 WL 157685 (S.D. Tex. Jan. 20, 2026), aff’d, 2026 WL 1611868 (5th Cir. June 4, 2026); Jarrus v. Governor of Michigan, 2025 WL 3461540, at *3 (E.D. Mich. Dec. 2, 2025), reconsideration denied, 2026 WL 27814, at *4 (E.D. Mich. Jan. 5, 2026) (pro se plaintiff sanctioned after being “warned that financial sanctions would be incurred at $200 per violation” –for each ChatGPT-generated hallucination; comparing amount to plaintiff’s annual ChatGPT subscription); United States v. Bendy, 2025 WL 3173897, at *2 (E.D. Tex. Nov. 13, 2025) (court refuses to accept pro se plaintiff’s unverified ChatGPT-generated filings); Morgan v. Sprouts Farmers Market, 2025 WL 2959489, at *1 (D. Ariz. Oct. 20, 2025) (pro se plaintiff who filed “lengthy” complaint including ChatGPT-generated “legal analysis” forbidden from using “Chat GPT or any similar form of artificial intelligence” in any refiled complaint); Powhatan County School Board v. Skinger, 2025 WL 1559593, at *11 (E.D. Va. June 2, 2025) (striking pleadings containing ChatGPT filed by likely judgment-proof pro se plaintiff); Gabriel v. SLS Lux Brickell Hotel, 2025 WL 2020154, at *5 (S.D. Fla. Jan. 15, 2025), (pro se plaintiff whose entirely generated complaint was dismissed “may not use ChatGPT to write his amended complaint”); Dukuray v. Experian Information Solutions, 2024 WL 3812259, at *11 (Mag. S.D.N.Y. July 26, 2024) (while “it is possible Plaintiff is not aware of the risk that ChatGPT and similar AI programs are capable of generating fake case citations and other misstatements of law . . ., it is no more acceptable for a pro se litigant to submit briefs with fake case citations than it is for a lawyer to do so”), adopted, 2024 WL 3936347 (S.D.N.Y. Aug. 26, 2024); Neal v. Sage Software LLC, 2024 WL 6915606, at *2, 7-8 (N.D. Ga. May 3, 2024) (entirely ChatGPT generated pro se complaint dismissed).

The continued employment of ChatGPT by lawyers, in particular, is distressing.  Indeed, the sheer number of cases we found from 2026 suggests that the problem is getting worse, not better.  Thus, we reiterate our prior advocacy of a stronger sanctions regime – particularly given the increased availability of generative AI models specifically designed for legal work.  We also suggest amending Rule 11 to remove AI-generated hallucinations from the requirement of filing a separate sanctions motion, since such violations are inevitably open-and-shut.