Hallucinations & Sanctions

AI & Law, Hallucinations & Sanctions

Kaufman v. Upton: Attorney Referred to Bar Overseers for AI-Generated Nonexistent Citations (D. Mass., Jan 2026)

A Massachusetts federal court referred attorney Roger Peace to the Massachusetts Board of Bar Overseers after he submitted AI-generated citations to nonexistent authority and gave an evasive response to the court’s show-cause order. The referral — rather than a direct sanction — represents a new mechanism for AI citation accountability.

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