Todd Blanche sanctioned by Seventh Circuit for AI hallucinations in legal brief

Lawyer Todd Blanche was sanctioned $5,000 by the Seventh Circuit Court of Appeals after filing a brief containing fabricated case law and false record representations generated by ChatGPT. The court also referred the matter to the Attorney Registration and Disciplinary Commission.

Todd W. Blanche (Acting Attorney General of the United States) · Incident Jun 1, 2026 · Indexed Jun 16, 2026 · 3 sources

nearly every quotation in the filing could not be traced to a real case, a known hallmark of AI hallucinations.
What
Lawyer Todd Blanche was sanctioned $5,000 by the Seventh Circuit Court of Appeals after filing a brief containing fabricated case law and false record representations generated by ChatGPT.
Incident date
Jun 1, 2026
Who
Todd W. Blanche (Acting Attorney General of the United States)
Failure mode
Hallucination
AI surface
Chatbot
Severity
High

What happened

Attorney Todd Blanche filed an opening appellate brief in the case Perez-Castillo v. Todd Blanche that contained numerous AI-generated hallucinations. The Seventh Circuit Court of Appeals found that approximately half of the cited cases were non-existent or falsely labeled, and nearly every quotation was untraceable. The filing also included false representations of the record regarding testimony and findings of the Immigration Judge.

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 attorney used ChatGPT to generate the brief and failed to review or verify the output before filing. The LLM hallucinated legal citations and quotes, which is a known failure mode of generative AI when producing specific legal references.

Public visibilityHigh
Regulatory exposureActive
Customer impactFew customers
Financial impactDisclosed
Time to disclosureDays
  1. PressSeventh Circuit Sanctions Attorney for Filing Brief with AI Hallucinations ~ Municipal Minutemunicipalminute.ancelglink.com
  2. Court Filing[PDF] Seventh Circuit - United States Court of Appealsmedia.ca7.uscourts.gov
  3. PrimaryAI Hallucination Cases Database - Damien Charlotindamiencharlotin.com
Permalinkhttps://failureindex.ai/failures/todd-blanche-sanctioned-seventh-circuit-hallucinations
CitationAI Failure Index. "Todd Blanche sanctioned by Seventh Circuit for AI hallucinations in legal brief" (FI-0581). Realm Labs. https://failureindex.ai/failures/todd-blanche-sanctioned-seventh-circuit-hallucinations (indexed Jun 16, 2026).
Share cardA branded image of this record for posts and slides.

Data fields CC-BY 4.0, prose citation permitted. Incident ID FI-0581. 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.