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How much are AI citation sanctions?

https://citationsafe.com/faq/how-much-are-ai-citation-sanctions

As of today, Citation Safe’s public sanctions database has 1,699 published rulings, 294 of which state a monetary penalty in some currency. Restricting to the 168 rulings denominated specifically in U.S. dollars: total penalties sum to $1,174,582, the average is $6,992, the largest single sanction is $110,204, and the smallest is $1 — a nominal, largely symbolic fine some courts impose alongside a non-monetary sanction like a bar referral.

Why these are live numbers, not a fixed snapshot

These figures are computed directly from the sanctions database at the moment this page is requested, not hand-typed into this page and left to go stale. As new rulings are ingested, the count, sum, average, and maximum above update automatically. The underlying, searchable dataset is at /sanctions-database.

Why the average is misleading on its own

An average of $6,992 is pulled upward by a small number of large adverse-costs orders — cases where the court awarded the opposing party’s full attorney’s fees on top of a sanction, sometimes totaling six figures. Most individual monetary sanctions in the database are far smaller: hundreds to a few thousand dollars, frequently paired with a non-monetary consequence (bar referral, mandatory CLE, striking the brief) that doesn’t show up in a dollar figure at all. See what sanctions have courts imposed for the non-monetary side of the picture.

Only part of the global picture

The USD figures above deliberately exclude every sanction denominated in another currency, rather than converting at an assumed exchange rate — a conversion would introduce a number nobody actually ordered. Here is the live currency breakdown across every published case with a stated monetary penalty:

USD is the largest single bucket, but ILS- and CAD-denominated sanctions are each a meaningful share of the total, reflecting that AI-hallucinated-citation sanctions are not a U.S.-only phenomenon — the full multi-currency dataset is browsable and filterable by jurisdiction at /sanctions-by-jurisdiction.

What the largest sanction on record actually breaks down to

The $110,204 figure for Couvrette v. Wisnovsky (D. Oregon, decided 2026-03-23) is not one line-item fine — the public record shows it as a combination: the offending brief was struck, a separate monetary sanction was imposed, and the court additionally ordered an adverse costs award covering the prevailing party’s fees. As the docket states it: "Briefs struck; Monetary sanction (15.5k); Adverse costs order (94.7k); claims dismissed with prejudice" The lesson generalizes across the database: the single largest number in a case is frequently an adverse-costs order layered on top of a smaller direct sanction, not the court picking one large round figure.

How courts decide the amount

The public record doesn’t show a formula, but a few recurring factors correlate with a larger sanction across the database: whether the filer was candid once confronted (a lack of candor is cited as an aggravating factor in more than one order), whether the fabrication was caught before or after it caused real litigation harm, whether it was an isolated citation or a pattern across many citations in the same brief, and whether real, quantifiable costs were imposed on the opposing party — which is what tends to drive the adverse-costs component into six figures. See which law firms have been sanctioned for named examples of each factor in practice.

Related resources

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Written by the Citation Safe Research Desk · Reviewed by Andy Gaber, Founder