Which law firm was sanctioned in the first widely reported AI-hallucination case?

Levidow, Levidow & Oberman, P.A., along with attorneys Steven Schwartz and Peter LoDuca, in Mata v. Avianca (S.D.N.Y. June 22, 2023) — $5,000 in joint-and-several Rule 11 sanctions after ChatGPT-fabricated citations were filed in an opposition brief.

Have any recent cases resulted in firmwide sanctions rather than just individual attorney sanctions?

Yes. McCormick v. Texakoma Financial (E.D. Texas, June 2026) ordered a firmwide citation review in addition to a public reprimand and monetary sanction, and In re the Marriage of Haddock (DC Oklahoma, May 2026) ordered a mandatory audit of the firm's knowledge base alongside a bar referral.

Do firms get sanctioned even if only one attorney used the AI tool?

Yes, when the firm is a named party to the filing or the sanctioning order extends supervisory responsibility to the firm — Mata's $5,000 sanction was joint and several against both individual attorneys and the firm itself.

Which law firms have been sanctioned for AI-hallucinated citations?

https://citationsafe.com/faq/law-firms-sanctioned-for-ai-citations

Real, named sanctions against law firms and attorneys for AI-hallucinated citations go back to Mata v. Avianca in 2023 and continue into 2026, with the more recent cases increasingly extending beyond a single attorney to firmwide remedial orders. Below are specific, sourced cases — every case name, court, date, and outcome links to the underlying database row.

The cases

ByoPlanet International v. Johansson and Gilstrap
S.D. Florida — decided 2025-08-01 — 85567 USD
Cases dismissed without prejudice, attorney ordered to pay defendants' attorney fees, referred to Florida Bar.
In re the Marriage of Amy Haddock and Justin Blu Haddock
DC Oklahoma — decided 2026-05-21 — 2000 USD
Monetary Sanction; Bar Referral; Mandatory Audit of Firm Knowledge base; Adverse Costs Order
Mata v. Avianca, Inc
S.D. New York — decided 2023-06-22 — 5000 USD
Monetary Fine (Lawyers & Firm); Letters to Client/Judges
McCormick v. Texakoma Financial
E.D. Texas — decided 2026-06-11 — 6000 USD
Public Reprimand; Monetary Sanction; Firmwide citation review; CLE

Mata v. Avianca — where firm-level sanctions started

The $5,000 sanction in Mata was joint and several against attorneys Steven Schwartz and Peter LoDuca and their firm, Levidow, Levidow & Oberman, P.A. — the court did not treat the misconduct as isolated to the individual who ran the ChatGPT queries, since LoDuca signed the filing without independent verification. This joint-and-several structure — individual attorney plus firm — recurs throughout the later record.

The 2026 trend: firmwide remedial orders

The two 2026 examples above show courts moving past a one-time fine toward structural remedies aimed at the firm’s process, not just the individual filing: a mandatory firmwide citation review in McCormick, and a mandatory audit of the firm’s internal knowledge base in the Haddock matter. Read together with the ByoPlanet International bar referral — where the court specifically noted the attorney’s lack of candor when confronted about AI use as an aggravating factor — the pattern suggests courts are increasingly treating a firm’s citation-verification process, not just a single attorney’s conduct, as the thing that needs fixing.

What this means for firm-level risk management

A firmwide citation-review order or knowledge-base audit is a court-imposed process fix — exactly the kind of control a firm can put in place proactively rather than by court order. See how to verify a legal citation manually for what that process actually requires per citation, and the full sanctions database for more examples across jurisdictions.

Related resources

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