Erin Booker v. The Kroger Co.
Decided 2026-08-28 · Outcome: Monetary Sanctions; CLE · Penalty: 8000 USD · AI tool: Unidentified.
4 sanctioned cases on record in N.D. Georgia where an attorney filed briefs, motions, or other pleadings containing AI-fabricated citations. Every entry below traces to a real, publicly reported court ruling. Data pulled daily from the underlying dockets and reporter databases — last update within 24 hours.
How courts in N.D. Georgia have responded when a filing contained fabricated citations.
Filings in this jurisdiction most often cite the tool as “Implied” (the ruling describes an AI-generated brief but does not name a product).
Across 4 documented sanctions in N.D. Georgia, the most common judicial response is Cle; Sworn Statement (1 of 4). Of the 4 cases, 2 carried an explicit monetary penalty in the ruling text.
The rulings in this jurisdiction are consistent with the pattern Citation Safe tracks nationally: when a court identifies a fabricated citation, the sanction almost always follows within days, not weeks. The attorney of record — not the AI — is on the hook. Rule 11 (federal), state analogs, and inherent authority all support monetary sanctions, disgorgement, adverse-costs orders, and bar referrals independent of the tool that produced the citation.
Practical implication: any brief that reaches a docket in N.D. Georgia needs a citation-existence check before filing. Existence is Layer 1 — the case has to be real. Layer 2 is quote accuracy (any quoted language must actually appear in the opinion). Layer 3 is propositional support (the opinion must actually stand for what you cite it for). Every documented sanction below failed at Layer 1 or Layer 2 — the kind of failure that is trivially catchable before filing and catastrophically visible after.
Sample penalty language from this jurisdiction: “8000 USD”; “1500 USD”.
Decided 2026-08-28 · Outcome: Monetary Sanctions; CLE · Penalty: 8000 USD · AI tool: Unidentified.
Decided 2026-01-21 · Outcome: CLE; Sworn statement · AI tool: Unidentified.
Decided 2025-12-30 · Outcome: Fine; Ordered to submit statement of training/oversight · Penalty: 1500 USD · AI tool: Implied.
Decided 2025-10-28 · Outcome: Order to notify clients; Order to file this opinion in all new cases for five years · AI tool: Implied.
Other courts on the Citation Safe sanctions database with a similar volume of AI-hallucination rulings on record.
3 free checks. No signup. Every citation checked against the primary source — not another AI. $19 unlocks the full annotated report.
Informational only. Not legal advice. Data derived from public court records; corrections at /contact.