2026-03
Hallucination
U.S. Court of Appeals for the Sixth Circuit

Sixth Circuit imposed $116K sanctions over AI-hallucinated appellate briefs

What happened

Two attorneys filed three appellate briefs that cited cases which did not exist and misrepresented the record — the fabrications characteristic of unchecked generative-AI legal research. The court found the fake citations clustered where little genuine authority existed and issued what was described as the largest sanction to date for AI-generated fake citations.

Impact

On 2026-03-23 the court ordered $116,315 in combined sanctions and referred both attorneys for disciplinary proceedings.

How this could have been prevented

Mandatory citation verification against an authoritative legal database before filing catches the nonexistent cases the AI invented.

Sources

More hallucination incidents

Would runtime governance have caught this?

Guardion enforces policy on every agent action inline — with visibility, tamper-evident evidence, and DLP for agents and MCPs.

Request a demo