What is the largest monetary sanction for an AI-hallucinated citation on record?

As of this writing, the largest USD-denominated sanction in Citation Safe's public database is $110,204 in Couvrette v. Wisnovsky (D. Oregon, 2026), combining a monetary sanction and an adverse costs order after the offending brief was struck.

Do courts ever impose no monetary penalty at all?

Yes. Park v. Kim (2d Cir. 2024) carried no monetary penalty — the sanction was a referral to the court's Grievance Panel and an order to disclose the misconduct to the client, which for a practicing attorney can be more consequential than a fine.

What sanctions have courts imposed for AI-hallucinated citations?

Q: What kinds of sanctions have courts imposed for AI-hallucinated citations?

Monetary fines, adverse costs orders, referrals to state bar disciplinary authorities, mandatory CLE, firmwide citation-review orders, striking of briefs, and dismissal of claims or appeals. Courts frequently combine several of these in a single order.

https://citationsafe.com/faq/sanctions-imposed-for-ai-hallucinated-citations

Court sanctions for AI-hallucinated citations range from a $1 nominal fine to six-figure adverse-costs orders, and money is often not even the harshest part of the order. As of today, Citation Safe’s public database tracks 1,699 published sanction rulings, 294 of which carried a stated monetary penalty in some currency.

The sanction types courts actually use

Monetary fines — Rule 11 or inherent-authority sanctions payable to the court or opposing party.
Adverse costs orders — the offending party pays the other side’s attorney’s fees and costs.
Bar referral — the matter is referred to a state bar disciplinary authority or, for federal appellate courts, a Grievance Panel.
Mandatory CLE or firmwide review — courts have ordered continuing legal education and audits of a firm’s citation-checking process.
Striking the brief — the offending filing is struck from the record, sometimes with the underlying claim dismissed.
Client disclosure order — the attorney must inform their own client of the misconduct, as in Park v. Kim.

Real cases, real outcomes

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.
Couvrette v. Wisnovsky
D. Oregon — decided 2026-03-23 — 110204 USD
Briefs struck; Monetary sanction (15.5k); Adverse costs order (94.7k); claims dismissed with prejudice
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
Park v. Kim
2nd. Cir. CA — decided 2024-01-30
Referral to Grievance Panel + Order to Disclose Misconduct to Client.

Why the range is so wide

Sanction severity tracks a few consistent factors across the database: whether the fabrication was caught before or after it caused real harm (Park v. Kim was caught by the court itself, materially worsening the outcome because opposing counsel never had a chance to flag it), whether the filer was candid when confronted (the ByoPlanet International order explicitly cites the attorney’s lack of candor as an aggravating factor), and whether it was a first offense or a repeat pattern within the same filing or across multiple filings. Courts consistently reject the argument that using an AI tool is itself a mitigating factor — see does Rule 11 apply to AI-generated briefs.

See the full range

For the complete, searchable set — 1,699 rulings, filterable by jurisdiction, AI tool, and year — see the full sanctions database. For just the aggregate monetary numbers, see how much are AI citation sanctions.

Related resources

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