TOV Realty, LLC v. Suarez / Kosel Equity, LLC v. MacGregor
The case
TOV Realty, LLC v. Suarez / Kosel Equity, LLC v. MacGregor, Conn. Supreme Court, SC 21183/21184, per curiam sanctions order July 31, 2026 (355 Conn. ORDERS 902): the court's first decision addressing sanctions over AI hallucinations. Attorney: Ian Gottlieb (GLG Law LLC). Primary order via the Connecticut Law Journal publications page, Vol. 355: Orders: https://jud.ct.gov/colp/publicat.htm ; reported at: https://www.reuters.com/legal/litigation/top-connecticut-court-warns-lawyers-ai-risks-after-fake-citations-2026-08-03/
What happened
In a landlord-tenant case, Gottlieb submitted filings containing seven erroneous and unverified citations generated by ChatGPT.
The rule and the sanction
Violation of the duty of competence (Rule 1.1) and related candor obligations. Sanctions: six additional CLE hours (three specifically on generative AI), $1,000 donations each by Gottlieb and his firm to the Connecticut Bar Institute, and compliance reporting. The court directed a courtesy copy of the order, expressly "not a referral", and its public posting.
How it could have been avoided
The drafts had been checked in LexisNexis/Shepard's, the hallucinations entered afterward, in a ChatGPT editing pass. Verification has to run after the last edit, not before it: any later pass that touches the text re-opens the duty to verify every citation. Small firms should adopt the same verification discipline as large ones; courts now expect baseline AI literacy from all counsel.