In re Eric Chibueze Nwaubani
The case
Attorney-discipline matter before the Fourth Circuit's Standing Panel on Attorney Discipline (2026), reported in the Norton Rose Fulbright 2026 sanctions update: https://www.nortonrosefulbright.com/en-us/knowledge/publications/792d8bf3/ai-in-litigation-update-on-gen-ai-sanctions-in-2026
What happened
Counsel's briefs in an employment-discrimination appeal cited three nonexistent cases. After the panel discovered one of them and ordered a revised brief and a show-cause response, his reply brief cited two more nonexistent cases (CFTC v. Glencore Ltd. and In re Acres Properties, Inc.). He denied using generative AI and offered what the court found to be attenuated explanations for the errors; the court expressly declined to decide whether he had used AI.
The rule and the sanction
The Standing Panel on Attorney Discipline publicly admonished him for conduct that seriously interfered with the administration of justice.
How it could have been avoided
A second defective filing after a show-cause order is the escalation that drives the top grade: the post-notice reply brief, not any denial, is what made this R5, the panel expressly declined to decide whether AI was used, so the denial was never adjudicated and bought nothing. Once a court flags a citation, audit every pending filing before anything else leaves the office, and verify citations before filing so there is nothing to explain away.