A lawyer faced a $15,000 sanction for AI-fabricated citations across three briefs
In an Indiana ERISA case, a federal magistrate judge recommended a $15,000 sanction against a solo practitioner who filed three briefs containing fake citations generated by AI, including a case that did not exist. The lawyer admitted he relied on generative AI and did not verify the cases.
Citing to a case that simply does not exist is something else altogether, the judge wrote.
Key facts
- What
- In an Indiana ERISA case, a federal magistrate judge recommended a $15,000 sanction against a solo practitioner who filed three briefs containing fake citations generated by AI, including a case that did not exist.
- Incident date
- Feb 1, 2025
- Who
- HoosierVac counsel (Mid Central v. HoosierVac)
- Failure mode
- Hallucination
- AI surface
- Chatbot
- Severity
- Medium
What happened
In a Southern District of Indiana ERISA case, attorney Rafael Ramirez cited a case that did not exist, then could not find it when ordered to. The judge found two more fabricated citations in his other briefs and recommended a $15,000 sanction for three AI-tainted filings, noting there is no reason an attorney cannot verify citations with standard tools.
What broke inside the model
- 01 · TriggerA user asks for a fact, a citation, or a figure.
- 02 · Model stepThe model writes a fluent, confident answer.
- 03 · Control gapNothing ties the claim back to a real source.
- 04 · FailureA fabricated fact ships as if it were verified.
- 05 · ConsequenceThe false claim reaches a customer, a court, or the public.
Confidence holds, and even spikes, as the claim detaches from any source.
The system produced fluent, confident output with no grounding in any source. Hallucination is a property of how the model generates, not a bug in one prompt: the most likely next token is not the same as the true one, and nothing in the pipeline compared the answer against a source of truth before it shipped.
What it cost
$15,000 recommended sanction; referral for further discipline
Sources
Cite this entry
https://failureindex.ai/failures/lawyer-faced-15-000-sanction-aiAI Failure Index. "A lawyer faced a $15,000 sanction for AI-fabricated citations across three briefs" (FI-0035). Realm Labs. https://failureindex.ai/failures/lawyer-faced-15-000-sanction-ai (indexed Jun 3, 2026).Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0035. Full dataset at /data.
Note from Realm Labs, the Index steward
How Realm would have caught this
- Prism
- OmniGuard
- AI Detection & Response (AIDR)
A runtime layer that watches the model's internal state can flag the moment a model commits to a claim it has no support for, and hold or reroute the response before it reaches a user. Realm reads those signals in real time rather than grading the transcript after the fact.