Sanctions in Dubinin v. Papazian for AI-generated fabrications in court filings

Two independent sources confirm that in Dubinin v. Papazian, AI-generated inaccuracies including nonexistent authorities and false quotations led to sanctions; the case was dismissed without prejudice and fees were ordered. The reporting outlets are independent and include a court filing that corroborates the sanctions.

Unknown · Incident Nov 21, 2025 · Indexed Jun 5, 2026 · 2 sources

AI hallucinations produced fabricated authorities and quotations in a court filing.
What
Two independent sources confirm that in Dubinin v.
Incident date
Nov 21, 2025
Who
Unknown
Failure mode
Hallucination
AI surface
Chatbot
Severity
High

What happened

On November 21, 2025, the U.S. District Court for the Southern District of Florida sanctioned the plaintiff's attorney for submitting AI-generated filings containing fabricated court authorities and quotations. The court dismissed the case without prejudice and ordered the attorney to pay the opposing party's fees. The court also referred all attorneys involved to their respective state bars for disciplinary action.

What broke inside the model

Failure path · mode profile · Hallucination
  1. 01 · TriggerA user asks for a fact, a citation, or a figure.
  2. 02 · Model stepThe model writes a fluent, confident answer.
  3. 03 · Control gapNothing ties the claim back to a real source.
  4. 04 · FailureA fabricated fact ships as if it were verified.
  5. 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 filing contained fabricated authorities and quotations generated by AI, which led to sanctions. The legal team did not sufficiently verify AI outputs before submission, resulting in the non-existent authority and false quotations being used in the court filing.

Public visibilityHigh
Regulatory exposureNone
Customer impactFew customers
Financial impactDisclosed
Time to disclosureDays
  1. PressAI IP Year in Review: AI Hallucinations in Court Filings and Orders , A 2025 Review of Sanctions Across the Courts and Rule Proposalssternekessler.com
  2. Court FilingDubinin v. Papazian (S.D. Fla., Nov. 21, 2025) - The court found the plaintiffs filings contained AI-generated inaccuracies, including nonexistent authorities and false quotations.hildasibrian.com
Permalinkhttps://failureindex.ai/failures/sanctions-dubinin-papazian-generated-fabrications-filin
CitationAI Failure Index. "Sanctions in Dubinin v. Papazian for AI-generated fabrications in court filings" (FI-0276). Realm Labs. https://failureindex.ai/failures/sanctions-dubinin-papazian-generated-fabrications-filin (indexed Jun 5, 2026).
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Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0276. Full dataset at /data.

Note from Realm Labs, the Index steward

How Realm would have caught this

Controls for this failure mode
  • 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.