Appeals Court Sanctions Lawyer Over AI-Hallucinated Errors

2026-02-09 · Source: Welcome to the Artificial Intelligence Incident Database · Field: Legal & Regulatory — Legal Technology (LegalTech), Compliance & Risk Management, Litigation & Dispute Resolution · Depth: Fundamental Awareness, short

Summary

A Maryland lawyer, Kusmin L. Amarsingh, received a \$1,000 sanction from the US Court of Appeals for the Tenth Circuit for submitting a brief containing "multiple nonexistent cases" and misattributed legal propositions. Amarsingh admitted using ChatGPT for research and drafting, which generated seven fabricated case citations. The Tenth Circuit, affirming the dismissal of her racial bias claims against Frontier Airlines Inc., also referred her conduct to Maryland's attorney-disciplinary authorities. This incident highlights a growing trend of lawyers facing sanctions for generative AI misuse in court filings. The court found Amarsingh's actions reckless under Federal Rule of Appellate Procedure 38, citing her complete failure to verify cited cases and quotations. Amarsingh has since completed a continuing legal education course on AI ethics and expressed commitment to preventing future errors.

Key takeaway

For legal professionals drafting court filings, your reliance on generative AI tools demands stringent verification protocols. You must personally confirm the existence and accuracy of every cited case and quotation, as objective recklessness, not subjective intent, determines sanctions under Federal Rule of Appellate Procedure 38. Failing to do so risks monetary penalties, disciplinary referrals, and the dismissal of your client's claims. Consider completing specialized continuing legal education on AI ethics to mitigate these professional liabilities.

Key insights

Legal professionals must rigorously verify all AI-generated content before submission to courts.

Principles

• Attorney conduct is judged by an objective recklessness standard.
• Confirming cited cases and propositions is a fundamental duty.

In practice

• Double-check all AI-generated legal citations for existence and accuracy.
• Undertake continuing legal education on AI ethics.

Topics

• Generative AI
• Legal Ethics
• Attorney Sanctions
• AI Hallucinations
• Appellate Procedure
• Legal Technology

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Editorial summary, takeaway, and curation by AIssential. Original article published by Welcome to the Artificial Intelligence Incident Database.