Lawyer Fined Twice for Fake AI Cases in Court

Episode 3 · Published September 25, 2026 · 11:00

He proposed his own “modest deterrent penalty” of $950 after already paying more than $73,000 in sanctions. The court called the situation “of his own making.”

Sanctions memorandum, Bunce v. Visual Technology Innovations (E.D. Pa.)

A Pennsylvania federal lawyer filed motions containing AI-hallucinated fake case citations. The Eastern District of Pennsylvania sanctioned him $2,500 plus an hour of mandatory CLE on AI and legal ethics in February 2025. A year later he did it again in a fight over deposition travel costs, and the April 2026 order doubled the fine to $5,000, added more ethics school, and warned that a third offense goes to the state's disciplinary board.

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Full transcript

This week's judge opened with a robot quote. It got worse from there. The first fine was $2,500 for citing cases that do not exist. You would think $2,500 teaches a lesson. The lesson is three words long. Check the cases. But the lesson did not take. A year later, the same lawyer filed another motion, with another made-up case, in a fight about his own sanctions. The judge opened his opinion with a line from a 1920 play about robots. He was warning you. I submitted to court, neglected to verify, sanctioned, for I judge read the filing, now they're gonna make you cry.

Hey everybody! Thanks for joining us on Sanctioned for AI. My name is Lucy Hatchett. I hold the deepest respect for the legal profession as a whole. But boy, do I have fun with these lawyers getting themselves into trouble. Three things today. Round one, the fake cases and the first fine. Round two, the re-offense and the excuses. Round three, the hammer. And hold one number for me, 950. You will see.

We are in a federal trial court in Pennsylvania, the Eastern District. The lawyer filed two motions, one to withdraw from the case, and one to appeal a sanctions order against him. The court checked the citations. Two of the cases do not exist, not on any legal research tool, not with any typo that explains it, both made up out of whole cloth. The rest were real cases, cited for things they do not say. One was about a doctrine called disentitlement. He cited it for something else entirely. Two more had been reversed or overruled. Dead law walk-in. His explanation? A popular chat bot wrote the motions. The program was new to him. A friend had suggested it. He said he never in his wildest dreams thought it would manufacture cases. He admitted he made no inquiry into whether any of it was real.

Here is the part that stings. He told the court he normally uses a different research program. He knew how to verify. He just skipped it this time with the new toy. The court's answer? In the order's own words. Those cases are, quote, as artificial as the intelligence behind them. And the lawyer was, quote, entirely reliant upon some computer, some machinery, to do the job that he was supposed to be doing.

Context. Because context matters. Rule 11 is the rule that says your signature on a filing is a promise. A promise that you checked the law and checked the facts. In plain English, sign it, you read it, or you should have. And here is the part lawyers should tattoo somewhere. Under rule 11, negligence is enough. Not bad faith, not intent. The court put it this way. Lawyers can be sanctioned for what they should have known, not just what they knew. That was February of 2025. The first sanction, a $2,500 penalty, plus one hour of CLE, that is continuing legal education, mandatory school for lawyers, on AI and legal ethics. The court said the point was deterrence, stop him, and warn everyone watching.

You know what they say about sequels. They are never as good as the original. This one was worse. So the lesson is learned, the fine is paid, everyone goes back to work. But the next fight in the case was about travel money for a deposition that got cancelled, and our hero answered with a combo motion, containing another made-up case. An omnibus motion is one big filing that bundles several requests, a combo meal, but for litigation. He used his to ask the court to sanction the other side, and to deny them the travel costs. The other side's response had a line for the ages, quote, the lawyer has once again used a made-up case and cited authorities that do not support his propositions. Once again. His reply to that accusation? A footnote. One footnote. The whole thing got a footnote.

Now this court had a standing order about AI. A standing order is a rule the court posts for every case. This one said, if you use AI on your citations, disclose it. And certify that every citation is verified as accurate. Disclose, then verify. In writing. The court ordered him to pay the travel costs, denied his combo motion, and told him to show cause. A show cause order is the judge saying, explain yourself or else. There was a hearing, and the excuses came out in formation.

Excuse one. The other side would not confer with him about the travel money. The court's answer. Full stop. Not a reason. Check the cases anyway. Excuse two. His deadline was about to expire, so he had to rush the filing. The court said he could have asked for an extension, which it would have readily granted. Instead, quote, he haphazardly filed an AI-generated document. Excuse three. He blamed the other side, doubled down, and argued the standing order never said the words human verification only. The court's review of that approach, quote, ill-advised, which is judicial for terrible idea, said politely. An excuse for my personal favorite. He does not normally practice law. He does, quote, business stuff. The court noted that any first semester, first year law student knows you check your citations. This man has been a lawyer for nearly 40 years.

Now the number. Remember 950? Here is where it comes from. 14 months. That is how long the first lesson lasted. February of 2025 to April of 2026. At the hearing, he asked the court for, quote, a modest deterrent penalty of $950. Modest. He said he had already paid more than $73,000 in sanctions in this case. $73,000. And the opening bid is $950. The court said no. The situation in the court's words was of his own making. The earlier sanctions were for separate conduct, and the pattern showed an inability or an unwillingness to fix the behavior. Then the court quoted his own words back to him. Quote, all I ask is that whatever the court thinks is reasonable and fair to stop me from this nonsense.

So here is round two of the sanctions. Second worst first. More mandatory courses on AI and legal ethics. Plus proof of the courses he already took. A lawyer of nearly 40 years, sent back to school. With a homework receipt. That was April of 2026. And the worst, $5,000. Double the first fine. The court said a smaller penalty for a second violation of the same rule would not fix a repeated behavior. The sequel cost double. The rest, a warning, written into the order. Do this a third time, and the court will sanction again, and send him to the state's disciplinary board. The gun is on the table, loaded. Safety off.

The court closed with an admonition to every lawyer reading. The law is a human enterprise. Do not get so comfortable with the tools that you forget your duties. To your clients, to the courts, to everyone. Because if you do, it will be your name and your license on the line. Not the chat bots. One more line from the order, for the road. The court wrote that lawyers must exercise, quote, pristine judgment when using AI. Pristine. Not pretty good. Not rushed before a deadline. Pristine. The sequel was worse than the original. First fine, $2,500. Second fine, $5,000. The lesson, priced to move. Verify, then file. Your signature is a promise that you checked. The chat bot cannot sign. You did.

He said it himself at the first hearing. Verification is the attorney's responsibility, not the algorithm's. And yes, an AI host just told you to double check the chat bot's work. I see the irony. Check anyway. Know a lawyer who lets the chat bot do the research? Send them this video. Lovingly. And subscribe so you never miss a sanction. I'm Lucy Hatchett. I will see you in the next one.

Sources

Shorts from this episode

He Told the Court He Does "Business Stuff." Any 1L Knows You Check Your Citations.

YouTube Short · October 6, 2026

Transcript

This Pennsylvania lawyer told the court he does not normally practice law. He does, quote, business stuff. He has been a lawyer for nearly 40 years. The court noted any first semester, first year law student knows, you check your citations.

Sources

He Proposed His Own $950 Penalty. He'd Already Paid $73,000. The Court Was Not Amused.

YouTube Short · October 6, 2026

Transcript

This Pennsylvania lawyer proposed his own sanctions of $950 for misusing AI after he'd already been hit with $73,000 in sanctions in an earlier round for separate conduct. The court was not amused.

Sources

Lawyer Fined for Fake Cases. Then Did It Again.

YouTube Short · October 7, 2026

Transcript

This Pennsylvania lawyer got fined for citing cases that do not exist. A year later, in a fight about his own sanctions, he filed another made-up case. Guess what the sequel cost him?

Sources

First Fine: $2,500. Second Fine: $5,000. The Sequel Cost Double. Strike 3? The Disciplinary Board.

YouTube Short · October 7, 2026

Transcript

This Pennsylvania lawyer's first lesson lasted 14 months. First fine, $2,500. Second fine, $5,000. The sequel cost double, and the court told him exactly what Strike 3 looks like.

Sources

About the host. Lucy Hatchett is an AI character, not a real person. Her voice is a designed synthetic voice and her on-screen avatar is generated. Read her full bio and disclosure.