Courts have sharply increased monetary sanctions against lawyers who file briefs containing fabricated artificial intelligence citations, but the escalating fines have not stopped the practice, Law.com reports.

This year, two lawyers who submitted court documents with fake citations and quotes received a record $110,000 fine. That figure marks a steep rise from the $5,000 penalty imposed in a then-landmark 2023 case that first brought the issue of AI-generated hallucinations in legal filings to national attention.

Even the threat of six-figure penalties has not deterred the conduct. A database of AI hallucination cases maintained by researcher Damien Charlotin now counts 1,430 such cases in the United States and more than 2,000 worldwide.

Stephen Gillers, a professor at New York University School of Law, told Law.com that monetary sanctions alone are unlikely to solve the problem. "Disciplinary action against the lawyers leading to a sanction of suspension of their right to practice law" would be a much more effective deterrent, Gillers said.

"That hits some harder than getting hit with the fine in the pocketbook," Gillers told Law.com. "It cuts off their source of income."

Courts have already begun imposing such discipline. In April, the Nebraska Supreme Court suspended an attorney who filed a brief containing 57 fabricated citations. In that case, the attorney initially denied using AI. In November 2023, a Colorado attorney received a one-year, one-day suspension for AI-generated citations after mistakenly blaming a legal intern for the mistakes.

The trajectory of sanctions is clear. What began in 2023 with a $5,000 fine in a single high-profile matter has grown into record monetary penalties and, in some jurisdictions, suspensions from practice. Yet the caseload keeps climbing. Charlotin's database shows the problem has spread well beyond the United States, with more than 2,000 documented instances worldwide.

For practitioners, the pattern carries a blunt warning. Monetary sanctions, however large, may be only the first step in a widening enforcement ladder. As the Nebraska and Colorado suspensions demonstrate, courts and disciplinary authorities are willing to cut off an offender's ability to practice entirely. Lawyers who rely on AI tools to draft briefs face growing exposure — not just financial, but professional — and can expect regulators to favor suspensions as the deterrent of choice if hallucinated citations continue to appear in filings. Verification of every citation before filing is now the baseline expectation.