Sanctions Reference

1,847 court decisionshave addressed AI-hallucinated authority.

Not all of them are sanctions. Many are warnings. But 131 carry a professional sanction, 319 carry a monetary penalty, and 722 involve a practising lawyer rather than a self-represented litigant.

Data: AI Hallucination Cases Database, compiled by Damien Charlotin · April 2023 to 4 August 2026 · damiencharlotin.com
1,847
Decisions worldwide across 41 jurisdictions
722
Involving a practising lawyer, not a pro se litigant
131
Carrying a professional sanction or disciplinary referral
$1.67M
Total US-dollar penalties across 319 penalised cases
The curve

Six decisions in the first quarter tracked. Now roughly four hundred.

Each bar is the number of decisions dated to that quarter. The rise reflects both wider AI use and courts actively looking for fabricated authority in a way they were not two years ago.

62023Q232023Q372023Q4102024Q152024Q2192024Q3252024Q4552025Q11202025Q22572025Q33962025Q44362026Q13962026Q21122026Q3

Showing the most recent quarters. The final bar is partial, covering only the portion of the quarter captured at export. Because the database records only decisions where a court explicitly found or clearly implied reliance on hallucinated material, it undercounts: filings that were never caught do not appear.

What courts found

Fabrication is the largest category, but not the only one.

A single decision often records more than one kind of defect, so these categories overlap. Fabricated authority is the failure mode that gets reported. Misrepresentation, where a real case is cited for something it does not hold, appears in 772 decisions and is far harder to catch by eye.

Fabricated authority1,539
Misrepresented authority772
False quotations504
Outdated or repealed law33
Where and in what

Concentrated in the United States. Spread across practice areas.

Top jurisdictions
USA1,278
Canada204
Australia97
UK61
Israel55
Italy15
Primary legal field
contract433
administrative248
civil rights190
employment168
tort160
other129
What it cost

The largest monetary penalties on record.

Median penalty where one was imposed is $1,500. The distribution has a long tail, and the tail is where fee-shifting and opposing-counsel cost awards live rather than flat Rule 11 fines.

CaseCourtDatePartyPenalty
Arabyads Holding Limited v. Gulrez Alam Marghoob AlamADGMDec 2025Lawyer$282,508
Couvrette v. WisnovskyD. OregonMar 2026Lawyer$110,204
ByoPlanet International v. Johansson and GilstrapS.D. FloridaAug 2025Lawyer$85,567
LiveVideo.AI Corp. v. RedstoneS.D. New YorkJun 2026Lawyer$80,056
Minjie Zheng v. ICANNC.D. CaliforniaDec 2025Pro Se Litigant$66,129
Howell Management Services, LLC v. Vashisht-RotaCA CaliforniaDec 2025Pro Se Litigant$64,235

US-dollar penalties only. Awards in other currencies are recorded in the source database and are excluded here rather than converted.

The attribution gap

In 1,637 of 1,847 decisions, the tool was never identified.

The database records a named AI tool in only 210 decisions. In the rest the court recorded the use as implied or unidentified. Courts are not, in general, able to establish which system produced the fabrication, and neither is the filer after the fact.

This is the case for an independent verification record.

When a filing is challenged, the question is not which model was used. It is what the filer did to check the output before it entered the record. Without a contemporaneous artifact, that answer is a recollection.

VariLegal produces a verification certificate at the time of checking, backed by evidence, provenance, and a SHA-256 integrity hash, independent of the AI system that generated the original output.

Method and source

Where these numbers come from.

Every figure on this page is computed from the AI Hallucination Cases Database, compiled and maintained by Damien Charlotin, research fellow at HEC Paris. The database is available at damiencharlotin.com/hallucinations and is updated continuously.

Its inclusion rule is strict: it records decisions where a court or tribunal explicitly found, or clearly implied, that a party relied on hallucinated material. Mere allegations are generally excluded. It does not attempt to capture the wider universe of fabricated citations that were never addressed by a court.

This page reflects an export covering April 2023 through 4 August 2026, comprising 1,847 decisions. Counts shift as new decisions are added, so the source database is authoritative over anything shown here. Category counts overlap where a decision records more than one kind of defect. VariLegal is not affiliated with the database or its maintainer.

The record is the defence.

VariLegal verifies AI-assisted legal work product against authoritative sources and produces an independent certificate before the document enters the record.

How VariLegal verifies