AI Risk Wire

Cases › made things up › LR-2026-0655

Federal appeals court refers Anthony Sabatini over AI-faked citations

Preliminary Why: Publisher not yet named · subject to change

Status: no action reported

Severity moderate
Reported 10 Jul 2026

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

A lawyer, Anthony Sabatini, filed appellate briefs in a pandemic-era lawsuit brought by aviation workers against Atlas Air and Flight Services International over COVID vaccine, testing and mask policies. The 11th U.S. Circuit Court of Appeals found the briefs contained fabricated case citations: the opening brief relied on at least eight nonexistent cases. After opposing counsel flagged the problem, Sabatini filed an untimely reply acknowledging the citations were erroneous or unverifiable and sought to withdraw eight cases. The withdrawn cases did not match the hallucinated ones, and all eight were also hallucinated. The court referred him to its Committee on Lawyer Qualifications and Conduct for possible discipline. Appellate costs were taxed against his clients.

What happened

1 · What went wrongThe opening brief relied on at least eight nonexistent cases.
2 · How it was caughtOpposing counsel flagged the problem, and Sabatini's untimely reply admitted the citations were erroneous or unverifiable.

What was done

No source states an action or fix.

Risks

Sorted by rule from the case's fields; not yet read from the sources.

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, what was done.

Show the full account: 2 items from the primary sources

What happened, in order

Not dated in the sources:

  • Opening brief filed relying on at least eight nonexistent cases.
  • After opposing counsel flagged the problem, Sabatini filed an untimely reply seeking to withdraw eight cases.
Show every field, with its source and grade

What happened

Earliest source we hold
2026-07-10
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

Impact

Severity
moderate
D inferred by us from the described behaviour, reason shown

Context

Country
United States
C one secondary source states it

Notes on gaps

The referral is a possible-discipline referral, not a finding of discipline. No remediation is reported in the sources.

LR-2026-0655 · version 1 · published 2026-11-01 after automatic checks; not yet checked field by field by a person · JSON