{"schema_version":"0.10.0","id":"LR-2026-0437","record_version":1,"title":"10th Circuit orders lawyer to pay $1,000 for faulty AI citations","verification":{"human_verified":false,"method":"automated_gate","auto_verified":true,"score":43.8,"score_breakdown":{"source_authority":12.1,"independent_corroboration":7.0,"implicated_party_confirmed":0.0,"citation_integrity":14.0,"specificity":0.0,"completeness":3.52,"unhedged_language":5.0},"checks":{"schema_valid":true,"every_field_cited":true,"quotes_verbatim":true,"source_fetched":true,"distinct_incident":true,"dates_plausible":true,"sources_agree":true,"source_describes_incident":true,"severe_backed_by_source":true,"record_integrity":true,"eligible":true,"about_this_case":true},"gate_version":"gate-2026-10-18.7","cross_check_model":null,"cross_check_agreement":null,"duplicate_of":null,"verified_by":null,"verified_at":"2026-11-01","extraction_run_id":null,"evidence_level":{"level":"preliminary","reason":"1 report: Colorado Politics · subject to change","original_document":null,"reports_total":1,"reports_independent":1,"reports_derivative":0,"developing":false,"disputed":false,"rules_version":"evidence-2026-10-29.1","computed_at":"2026-11-01","history":[{"date":"2026-11-01","from_level":null,"to_level":"preliminary","reason":"1 report: Colorado Politics · subject to change"}]},"sources_hash":"373d8e8370edc6aaad060569cab2fcdb698de08d410d9a16f9805ac2846886dc"},"system":{"model_name":null,"model_version":null,"developer":"unknown","harness":null,"tools_granted":[],"permissions_scope":null,"autonomy_level":"unknown","guardrails_present":[],"deployment_context":"unknown","tier":null,"lifecycle_stage":null,"integration_type":null,"intended_use":"legal research and drafting","safeguard_state":null,"production_intended":null},"event":{"date_occurred":null,"date_disclosed":"2026-02-09","incident_class":"hallucination","failure_class":null,"agent_involved":null,"secondary_failure_classes":[],"trigger":"unknown","duration":null,"detection_method":"third_party","summary":"A self-represented lawyer, Kusmin Linda Amarsingh, used ChatGPT for legal research and drafting in her appeal against Frontier Airlines over a discrimination claim. The filing cited seven cases that did not exist and included a non-existent quote from a case. The Tenth Circuit panel asked her to explain after the airline's lawyers could not locate several of the cited cases. Amarsingh said she had relied on the tool and had not checked the quotations against the case texts. The panel appreciated her honesty and her commitment to being more careful, but ordered her to pay Frontier $1,000 for its attorneys' expenses in responding to the fake citations. The clerk was also directed to forward the order to attorney regulators in Maryland, where she is licensed.","tags":[],"date_detected":null,"near_miss":null,"root_cause":"oversight","root_cause_detail":null,"failure_class_detail":null,"responsible_party":null,"adversarial_actor":null,"input_provenance":null,"time_to_contain":null,"operations_paused":null,"remediation":null,"precursor_events":null,"primary_risk":"RK14"},"impact":{"direct_loss_usd":null,"remediation_hours":null,"records_exposed":null,"third_parties_affected_count":null,"severity":"minor","severity_because":"Test: moderate needs data or systems of others touched with a bounded scope, which the sources do not state; the only effect stated is a $1,000 payment for the opposing party's attorneys' expenses, so the tier is minor.","harm_class":["financial"],"affected_description":null,"protected_class_involved":null,"data_categories_exposed":[],"loss_range_usd":null,"reversibility":null,"downstream_exposure_count":null},"evidence":{"sources":[{"url":"https://www.coloradopolitics.com/2026/02/09/10th-circuit-orders-lawyer-to-pay-1000-for-faulty-ai-citations/","publisher":"Colorado Politics","date":"2026-02-09","type":"press","title":"10th Circuit orders lawyer to pay $1,000 for faulty AI citations - Colorado Politics","archived_url":null,"attachment":"first_report","independence":"independent"}],"per_field_confidence":{"system.intended_use":"C","event.incident_class":"C","event.detection_method":"C","event.root_cause":"C","impact.harm_class":"C","impact.severity_because":"D","impact.severity":"D","event.primary_risk":"D","event.summary":"C","system.autonomy_level":"D","system.deployment_context":"D","event.trigger":"D","context.country":"D","system.developer":"D","event.date_disclosed":"D","context.denominator_available":"D"},"field_citations":{"system.intended_use":[{"source_index":0,"quote":"The seven nonexistent cases “were, regrettably, the result of my reliance on generative AI tools, specifically ChatGPT, to assist in legal research and drafting,” she wrote."}],"event.incident_class":[{"source_index":0,"quote":"The Denver-based federal appeals court ordered a lawyer on Monday to pay $1,000 to the opposing side for submitting a legal filing with fake case citations generated by artificial intelligence."}],"event.detection_method":[{"source_index":0,"quote":"After the airline’s lawyers noted they were “unable to locate several cases cited by Plaintiff,” the panel issued an order in September asking Amarsingh to explain herself."}],"event.root_cause":[{"source_index":0,"quote":"I mistakenly assumed that ChatGPT’s output was accurate and failed to cross-reference the quotations with the actual case texts."}],"impact.harm_class":[{"source_index":0,"quote":"Nonetheless, the panel ordered her to pay Frontier $1,000 for its attorneys’ expenses in responding to the fake citations."}],"impact.severity_because":[{"source_index":0,"quote":"Nonetheless, the panel ordered her to pay Frontier $1,000 for its attorneys’ expenses in responding to the fake citations."}],"impact.severity":[{"source_index":0,"quote":"Nonetheless, the panel ordered her to pay Frontier $1,000 for its attorneys’ expenses in responding to the fake citations."}],"event.summary":[{"source_index":0,"quote":"The Denver-based federal appeals court ordered a lawyer on Monday to pay $1,000 to the opposing side for submitting a legal filing with fake case citations generated by artificial intelligence."},{"source_index":0,"quote":"Amarsingh, who described herself as a military lawyer with some state court experience, represented herself in suing Frontier Airlines for discrimination."},{"source_index":0,"quote":"After the airline’s lawyers noted they were “unable to locate several cases cited by Plaintiff,” the panel issued an order in September asking Amarsingh to explain herself."},{"source_index":0,"quote":"I mistakenly assumed that ChatGPT’s output was accurate and failed to cross-reference the quotations with the actual case texts."},{"source_index":0,"quote":"Nonetheless, the panel ordered her to pay Frontier $1,000 for its attorneys’ expenses in responding to the fake citations."},{"source_index":0,"quote":"In the 10th Circuit’s decision, Hartz wrote that the panel appreciated Amarsingh’s honesty and her commitment to being more careful going forward."}]},"notes_on_gaps":"The sources do not state the AI developer, model version, deployment context, lifecycle stage, autonomy level or whether an autonomous agent was involved, so those fields are omitted. No filing date is stated, so date_occurred is omitted. The sources do not state the year of the September order, so only the month is recorded. The $1,000 sanction is a payment to the opposing party, not a stated loss figure, so direct_loss_usd is omitted. No control is stated as held, failed, got around or missing in the system, so links are empty. The sources report no change made afterwards, only a judicial sanction and a regulator referral, so remediations are empty. Judgements made: root_cause set to oversight and responsible_party to deployer, based on the filer's own statement that she did not cross-reference the output; severity set to minor because the sources state no data or systems of others touched and no bounded scope test is met for moderate; detection_method set to third_party because the opposing counsel flagged the missing cases. The December case involving a different self-represented plaintiff is excluded as a separate incident. [case created by the backfill: read by claude-haiku-5-5, backfill-2026-11-01.2, 2026-11-01; not yet reviewed] [2026-11-01: evidence level set: Preliminary (1 report: Colorado Politics · subject to change)]"},"context":{"industry":null,"org_size_band":null,"country":"unknown","denominator_available":false,"denominator":null,"related_incident_ids":[],"systemic_exposure":null,"shared_model_id":null,"upstream_incident_id":null,"incident_evidence":null,"regulatory":null,"coverage":null},"narrative":{"steps":[{"step":"went_wrong","text":"Seven cited cases did not exist, and one quote attributed to a case was not real; the filer said she relied on ChatGPT output.","quote":"The seven nonexistent cases “were, regrettably, the result of my reliance on generative AI tools, specifically ChatGPT, to assist in legal research and drafting,” she wrote.","source_index":0,"grade":"C"},{"step":"reached","text":"The fake citations appeared in a legal filing submitted to the Tenth Circuit.","quote":"The Denver-based federal appeals court ordered a lawyer on Monday to pay $1,000 to the opposing side for submitting a legal filing with fake case citations generated by artificial intelligence.","source_index":0,"grade":"C"},{"step":"caught","text":"Frontier's lawyers could not locate several cited cases and flagged it; the panel then asked the filer to explain.","quote":"After the airline’s lawyers noted they were “unable to locate several cases cited by Plaintiff,” the panel issued an order in September asking Amarsingh to explain herself.","source_index":0,"grade":"C"}],"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://www.coloradopolitics.com/2026/02/09/10th-circuit-orders-lawyer-to-pay-1000-for-faulty-ai-citations/"]},"analysis":{"sections":{"timeline":[{"text":"Magistrate judge recommended dismissing the underlying discrimination lawsuit.","quote":"In August 2024, U.S. Magistrate Judge Kathryn A. Starnella recommended dismissing Amarsingh’s lawsuit because she had not plausibly alleged racial discrimination.","source_index":0,"when":"August 2024"},{"text":"Frontier's lawyers reported they could not locate several cited cases; the panel ordered Amarsingh to explain.","quote":"After the airline’s lawyers noted they were “unable to locate several cases cited by Plaintiff,” the panel issued an order in September asking Amarsingh to explain herself.","source_index":0,"when":"September"},{"text":"Amarsingh responded that the seven nonexistent cases resulted from her reliance on generative AI tools.","quote":"The seven nonexistent cases “were, regrettably, the result of my reliance on generative AI tools, specifically ChatGPT, to assist in legal research and drafting,” she wrote.","source_index":0,"when":null}]},"model":"claude-haiku-5-5","prompt_version":"backfill-2026-11-01.2","extracted_at":"2026-11-01","source_urls":["https://www.coloradopolitics.com/2026/02/09/10th-circuit-orders-lawyer-to-pay-1000-for-faulty-ai-citations/"]}}