A lawyer who was previously disciplined twice for abusing artificial intelligence has been reprimanded again by a federal judge after including fabricated AI quotes in a lawsuit against entertainment company Roc Nation.
A growing number of lawyers face serious penalties for using artificial intelligence to draft court papers without verifying the work. By mid-2026, courts had recorded 1,667 cases in which lawyers filed fake legal citations generated by AI tools.
AI hallucinations lead to lawyers being fined
According to a global database tracked by researcher Damian Charlotin, lawyers have misused artificial intelligence in up to 1,667 court cases. This abuse centers around adding fake AI-generated citations to official court documents. The frequency of these incidents has increased by approximately seven times the number recorded in the previous year, which amounted to 230 incidents.
Recently, U.S. Magistrate Judge Jennifer Willis issued an order saying that attorney Tyrone Blackburn demonstrated a “persistent pattern of conduct” related to artificial intelligence after discovering that his file contained citations that did not appear in the cases he cited.
Willis wrote that Blackburn’s conduct was an “egregious violation of his ethical and professional obligations.” He was already punished in December for citing non-existent cases he created Artificial intelligence hallucinations In New Jersey federal court. A federal judge in Pennsylvania fined him $5,000 for allegedly fabricated quotes last year.
Lawyer cites AI hallucinations in Roc Nation lawsuit
In the latest case, Blackburn filed a lawsuit on behalf of Terrance Dixon, an artist and collaborator of rapper Fat Joe. Dixon alleges that the musician and his management company Roc Nation engaged in business-related misconduct. Dixon claims lost wages and other damages. Roc Nation and Fat Joe have it He denied these accusations.
Roc Nation asked the court last month to punish Blackburn for pursuing what it described as baseless allegations. She then urged the court to throw out Blackburn’s opposition, saying it was filed too late and contained what appeared to be the case AI hallucinogenic quotes.
Blackburn tried to double down, claiming that every court decision he cited was factual, although he said he had paraphrased some of the material. Judge Willis said Blackburn’s explanation “brazenly belittles” his behaviour.
Blackburn said he would respond to the court order but insisted on denying it.
In another incident, U.S. District Judge Sharion Aycock of the Northern District of Mississippi disqualified all four attorneys in a contract case after finding that attorneys on both sides had filed hallucinatory citations. Conflict The matter itself was simple: Attorney Tom Withers filed one suit for breach of contract against the city of Aberdeen for unpaid legal fees.
Withers represents himself here only nominally and is not punished. However, two of his lawyers and city representatives were not so lucky. Katherine Williams admitted to using an AI research tool, and Kathleen Wilson admitted to using generative AI to formulate a response, without verifying the results before submitting them.
Wilson’s argument was that she did not know that artificial intelligence could fabricate cases and she did not know what a hallucination was.
Aycock described the defense as “inadequate and unbelievable.” Not only did it cancel the trial, but it also fined the lawyers between $1,000 and $3,500. Furthermore, Williams and Wilson were banned from entering their district courts for two years.
Where else do artificial intelligence hallucinate?
Sullivan & Cromwell, one of the most established firms on Wall Street, told a New York federal court in April 2026 that a file containing hallucinatory errors had been entered into the Prince Group case.
Andrew Dietderich, co-chair of the company’s restructuring group, apologized in a letter to Judge Martin Glenn for a series of errors that included misquoting the U.S. Bankruptcy Code and incorrectly citing cases.
The company said its AI policies were not followed, and that a second review did not include bad citations before the file was published. A competing firm in this case, Boies Schiller Flexner, Arrest them.
Sullivan and Cromwell represented the liquidators who were pursuing the Prince Group, which was controlled by Chinese-born businessman Chen Zhi.
US prosecutors charged Chin Chee with wire fraud and money laundering last year in what they described as forced labor complexes in Cambodia. Separately, prosecutors moved to seize nearly $9 billion in bitcoin that authorities allege came from the group’s activity. Chen was arrested in Cambodia and extradited to China.
Why do AI legal tools keep making mistakes?
Tests conducted on two major legal research platforms, the artificial intelligence tools Lexis+ AI and Thomson Reuters (NYSE:TRI), found false information in more than 17% of cases. In some tests, error rates reach 34%.
In February 2026, the National Center for State Courts warned that AI hallucinations pose a growing threat to the justice system.
While lawyers are not prohibited from using AI, they do have an ethical duty to ensure that everything they submit is accurate.
The American Bar Association warned against failing to verify AI output in June 2025, stating that doing so could violate a lawyer’s duty to provide competent representation, but these sanctions show that many lawyers have not taken that warning seriously.
