AI Risk Wire

Cases › made things up › LR-2026-0368

Lawyer sanctioned over hallucinated material in OnlyFans case

Preliminary Why: Publisher not yet named · subject to change

Status: action reported, no fix

Severity minor
Reported 16 Dec 2025
Industry legal services

No source states: loss or records, developer and model, agent tool, could do, deployer.

Severity minor: Test: minor (contained to one deployer or one evaluation). Fact: the sanctions fall on one law firm and one lawyer in one lawsuit, and the source states no third party's data or systems were touched.

A federal judge in California fined a plaintiffs law firm and one of its partners $10,000 for misusing artificial intelligence in a lawsuit involving the parent company of OnlyFans. The judge also imposed a $3,000 sanction on co-counsel Celeste Boyd, who he said used ChatGPT to draft and edit portions of the briefs without verifying the material. The judge found the firm violated a rule requiring legal arguments to be warranted by existing law when four briefs included hallucinated material. The firm's partner, Robert Carey, said no one at Hagens Berman used AI when preparing the briefs and that outside co-counsel added the fake citations without adherence to the firm's AI protocols. Neither the firm nor Boyd responded to Reuters' request for comment.

What happened

1 · What went wrongCo-counsel used ChatGPT to draft and edit portions of the briefs and did not verify the material, according to the judge.
2 · How it was caughtThe judge found that four briefs included hallucinated material and that the firm violated a rule requiring legal arguments to be warranted by existing law.

What was done

The judge fined the firm and one partner $10,000 and imposed a $3,000 sanction on co-counsel.

Risks

Made-up output relied on
Primary36 incidents

Read from the sources; not yet reviewed by a person.

Controls

Not yet read for controls. Controls that mitigate the primary risk:

Application

Grounding and fact checks · Human approval for high-impact actions · Output filtering and redaction · People told they are dealing with AI

Evidence

No source states: what the AI was doing, what it reached or did, when it happened, when it was found, how many records were exposed, the direct loss, a count of the other parties affected, any court case, the cause, what set it off.

Show every field, with its source and grade

What happened

Earliest source we hold
2025-12-16
D inferred by us from the described behaviour, reason shown
Cause in detail
Co-counsel used ChatGPT to draft and edit portions of the briefs and did not verify the material
C one secondary source states it
What went wrong
made things up
C one secondary source states it
primary risk
RK14
D inferred by us from the described behaviour, reason shown

Impact

Severity
minor
D inferred by us from the described behaviour, reason shown
Why this severity
Test: minor (contained to one deployer or one evaluation). Fact: the sanctions fall on one law firm and one lawyer in one lawsuit, and the source states no third party's data or systems were touched.
D inferred by us from the described behaviour, reason shown

Context

Industry
legal services
C one secondary source states it
Country
United States
C one secondary source states it

Notes on gaps

The sources do not give the date of the ruling or the date of disclosure beyond the article date, so no event dates are set. No remediations are stated in the sources.

LR-2026-0368 · version 1 · published 2026-11-01 after automatic checks; not yet checked field by field by a person · JSON