Kusmin L. Amarsingh v. Frontier Airlines, Inc.
The case
Kusmin L. Amarsingh v. Frontier Airlines, Inc., No. 24-1391 (10th Cir.), order and judgment filed February 9, 2026. Amarsingh is an attorney admitted in Maryland; the court declined to extend her the leeway given to nonlawyer pro se litigants. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-126-amarsingh-v-frontier.pdf`. Source URL: https://www.damiencharlotin.com/documents/1484/Amarsingh_v._Frontier_Airlines.pdf
What happened
Amarsingh admitted she used ChatGPT as a research and drafting aid for her appellate brief. The tool generated seven fabricated case citations, and she also misattributed propositions and quotations to two real cases. She admitted she never verified that the seven cases existed or that the quotations appeared in the real cases.
The rule and the sanction
The court imposed sanctions under Federal Rule of Appellate Procedure 38, finding the appeal frivolous as argued (briefs containing nonexistent cases and misrepresentations of law). Sanctions: Amarsingh must pay $1,000 to Frontier within 30 days to offset its attorney fees and costs, with a sworn certification of compliance filed with the court; and the clerk was directed to transmit the order to the appropriate Maryland attorney-disciplinary authority. The appeal was affirmed on the merits.
How it could have been avoided
(a) Confirm that every cited case exists in a legal database before an appellate filing, especially when ChatGPT generated the research. (b) Read each quoted opinion to verify the quotation is real; two real cases here were misquoted. (c) Attorney pro se status does not lower the duty: courts hold lawyer-litigants to lawyer standards.