U.S. courts have imposed at least $145,000 in sanctions against attorneys in the first quarter of 2026 alone for briefs containing AI-generated citation errors. The figure is preliminary, almost certainly undercounts quiet settlements, and already represents more than any full year prior.
The tone of the underlying orders has shifted. Early in the AI-hallucination-in-court cycle, judges issued warnings and mild sanctions while the profession adjusted. The orders issued in 2026 read differently: less novelty, more exhaustion, and a growing willingness to treat fabricated citations as ordinary professional malpractice.
The practical guidance to law firms is now unambiguous. Every citation in every filing must be verified by a human against the authoritative source. Firms relying on AI drafting without a structured verification step are one bad Monday away from a sanctions order and a client conversation they did not want to have.