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ARTICLE · 15 JULY 2025

Court Sanctions Attorneys For Submitting Brief With AI-Generated False Citations

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Federal Rule of Civil Procedure 11 requires attorneys to verify the accuracy of court filings — including those prepared or supplemented with AI tools.

United StatesTechnology
Kaitlyn E. Stone
Kaitlyn E. Stone
William M. Carlucci
William M. Carlucci
Bryan Castro
Bryan Castro
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Highlights

  • Federal Rule of Civil Procedure 11 requires attorneys to verify the accuracy of court filings — including those prepared or supplemented with AI tools. 
  • All outputs from AI used in legal research must be closely scrutinized to ensure their accuracy. 
  • Failure to verify AI outputs used in court filings can lead to monetary or other sanctions. 

The U.S. District Court for the District of Colorado has sanctioned two attorneys for submitting a brief containing “nearly thirty defective citations” that were generated by artificial intelligence.

According to the court, the brief:

  1. Misquoted cited cases
  2. Misstated the holdings of cited cases
  3. Cited cases for legal principles not discussed in those cases

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