Case D-34 · AI Sanctions Case Tracker

Lexos Media IP LLC v. Overstock.com

U.S. District Court for the District of Kansas, sanctions order February 2, 2026 (Judge Julie A. Robinson)

The case

Five co-counsel for plaintiff Lexos Media IP LLC, D. Kan., following a December 2025 order to show cause; sanctions order February 2, 2026. Reported: https://www.findlaw.com/legalblogs/practice-of-law/judge-strikes-hallucinated-citations-from-brief-with-no-leave-to-amend/ (with link to the order via CourtListener)

What happened

The team filed a response to a motion to exclude expert testimony containing nonexistent quotations, misrepresentations of cited authority, and nonexistent or incorrect citations, including fabricated quotations attributed to real cases, among them i4i Ltd. Partnership v. Microsoft Corp. No one on the team checked the AI-derived research before signing; the drafting attorney admitted he had not checked the AI-generated results. The order records that he was dealing with serious family health emergencies at the time, and notes that he could instead have sought an extension of time.

The rule and the sanction

The court found all five Lexos attorneys in violation of Fed. R. Civ. P. 11(b) and publicly admonished them ($12,000 in fines total). Sandeep Seth (the drafting attorney) was fined $5,000, had his pro hac vice admission revoked, was ordered to self-report to state disciplinary authorities, and must file a certificate of new firm verification procedures by February 28, 2026. Kenneth Kula and Christopher Joe (Buether Joe & Counselors) were each fined $3,000 for signing documents without review (Joe must also file a firm-procedures certificate). Local counsel David Cooper (Fisher, Patterson, Sayler & Smith) was fined $1,000 for not checking the citations. Michael Doell was publicly admonished but released from further sanctions. The defective material was struck with no leave to amend, potentially fatal to the plaintiff's opposition. Sources: primary order (via Justia): https://cases.justia.com/federal/district-courts/kansas/ksdce/2%3A2022cv02324/142916/218/0.pdf ; https://www.reuters.com/legal/litigation/judge-fines-lawyers-12000-over-ai-generated-submissions-patent-case-2026-02-03/

How it could have been avoided

On a team filing, every signer must verify, "someone else checked" is not a defense. Firms need a written AI-verification procedure in place before, not after, the sanctions order.