Court Filings, Hallucinations & Sanctions · November 2026
Tov Realty, LLC v. Suarez
Connecticut Supreme Court sanctions attorney and firm after ChatGPT inserted hallucinated citations into drafts during proofing, unbeknownst to the attorney.
355 Conn. 902, 360 A.3d 1062 (2026)
In preparing appeal applications and supporting briefs, counsel used LexisNexis to conduct legal research and verified the accuracy of his citations and quotes using LexisNexis’s Shepard’s Citations Service. He then copy and pasted his work product into ChatGPT to improve his writing. Though he did not ask it to, ChatGPT added new case citations and altered existing citations, making the final documents inaccurate, though the legal propositions asserted were still substantively accurate and “well established.”
Counsel only became aware of the hallucinated cases when they were pointed out in various amicus curiae, and he then filed errata sheets and corrected the affected briefs.
Addressing the issue for the first time, the court held that filing approximately seven erroneous, unverified citations violated the duty of competence under Rule 1.1, even though the conduct was negligent rather than intentional. Sanctions included additional CLE (including on generative AI), $1,000 donations each by the attorney and firm, a compliance report, and posting of the order on the Judicial Branch website.