AI Risk Wire

Cases › made things up › LR-2026-0600

GenAI sanctions reach TCPAWorld litigation

Preliminary Why: 1 report: The National Law Review · subject to change · 1 independent report

Status: action reported, no fix

Severity minor
Reported 19 Jun 2026

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

Severity minor: contained to one case between the parties; no third party is stated as affected.

A law firm's brief in McCormick v. Texakoma Financial, a Telephone Consumer Protection Act case in the Eastern District of Texas, was filed in response to a summary judgment motion. The opposing party's reply identified a fictitious case, fictitious quotes and unsupported propositions in the response. The court issued an order to show cause requiring the plaintiff's attorney to appear with copies of the cases she cited. The attorney attributed the citation to a law clerk and a paralegal. The source reports that generative AI may have been used in drafting, though the attorney could not confirm it. On June 11, 2026 the court imposed financial sanctions and a public reprimand, and ordered verification of authorities in future filings and CLE on AI ethics.

What happened

1 · What went wrongThe response cited a fictitious case and fictitious quotes, which the defendant identified in its reply.
2 · How it was caughtAfter reviewing the reply, the court ordered the plaintiff's attorney to appear with copies of the cases she cited.

What was done

The court imposed financial sanctions and a public reprimand on the attorney.

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 the full account: 4 items from the primary sources

What happened, in order

  1. 2026-06-11 The court issued financial sanctions and a public reprimand.

Not dated in the sources:

  • The reply identified a fictitious case and fictitious quotes in the response.
  • The court issued an order to show cause.
  • The court noted the database of AI hallucination cases grew from 239 cases in February 2026 to 434 cases in June 2026.
Show every field, with its source and grade

What happened

Earliest source we hold
2026-06-19
D inferred by us from the described behaviour, reason shown
Who caught it
an outside party
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
contained to one case between the parties; no third party is stated as affected.
D inferred by us from the described behaviour, reason shown

Context

Country
United States
C one secondary source states it

Notes on gaps

The attorney's account (a law clerk or paralegal drafted or filed the wrong draft) is contested by the court and the article's author, and is reported here only as her claim. The remediation is advice from the article's author and the court's sanction orders, not a change reported by the party. Timeline dates for the show-cause order, the response, and the reply are not stated.

LR-2026-0600 · version 1 · published 2026-11-01 after automatic checks; not yet checked field by field by a person · JSON