# Legal AI Compliance Tracker: full datasets (plain text) > A free, independent, plain-English tracker of U.S. state bar ethics opinions, court rules, and official guidance on lawyers using generative AI. Every entry is verified against its primary source; sourcing limits and deferrals are documented in the methodology. Entries are labeled by type. Maintained by MHSB Solutions. Legal information, not legal advice. License: CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/) Attribution: Legal AI Compliance Tracker (https://legalaicompliance.help), maintained by MHSB Solutions Site last updated: 2026-08-04 Generated from the same data as https://legalaicompliance.help/data/opinions.json and https://legalaicompliance.help/data/sanctions.json on every build. How to read this file: "Type" is one of formal_opinion, guidance, report, court_rule, or proposed; never cite guidance as an "opinion." "Date" carries a precision flag (day, month, or year) stating how much of the date the primary source supports; never cite a more specific date than the precision allows. Methodology: https://legalaicompliance.help/methodology/ ## Instruments (55) Newest row-level verification date: 2026-07-19 ### ABA Formal Opinion 512: Generative Artificial Intelligence Tools - Jurisdiction: American Bar Association (national) - Type: formal_opinion - Date: 2024-07-29 (precision: day) - Status: current - Key duties: competence, confidentiality, communication, candor, supervision, fees - Primary source: https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf - Last verified: 2026-06-10 - Tracker id: aba-formal-opinion-512 The ABA's first and still-current ethics opinion on generative AI. Lawyers must understand the benefits and risks of the tools they use, protect client confidences before entering them into AI tools, communicate with clients about AI use where material, verify outputs, supervise AI use across the firm, and bill only for actual time spent prompting and reviewing, not for time spent learning the tool. Notes: No superseding ABA opinion on generative AI exists as of June 2026. Subsequent ABA opinions 514 through 518 cover non-AI topics. ### Formal Opinion 2026-01: Artificial Intelligence Use — Best Practices Under Existing Professional Conduct Rules - Jurisdiction: Alabama State Bar (Office of General Counsel) - Type: formal_opinion - Date: 2026 (precision: year) - Status: current - Key duties: competence, confidentiality, supervision, candor, fees, communication, verification - Primary source: https://www.alabar.org/office-of-general-counsel/formal-opinions/artificial-intelligence-use-best-practices-under-existing-professional-conduct-rules/ - Last verified: 2026-07-19 - Tracker id: alabama-formal-opinion-2026-01 The Alabama State Bar's numbered Formal Opinion 2026-01, an eleven-page opinion on generative and agentic AI in law practice. Its premise: artificial intelligence does not create new ethical duties but recontextualizes longstanding obligations of competence, confidentiality, supervision, candor, reasonableness of fees, and client communication, with the lawyer fully responsible for all work regardless of AI use, citing ABA Formal Opinion 512. It treats AI ethically as a non-lawyer assistant requiring supervision, addresses vendor selection as a competence issue, prefers closed non-training enterprise systems over consumer tools, treats AI subscription costs as overhead absent client agreement, requires honest answers when clients ask about AI use, and closes with a per-matter checklist: check the court's local rules and standing orders for AI disclosure or certification requirements, document the tool used, the task performed, and the verification steps taken, confirm that no legal judgment, strategic decision-making, or client advice was delegated to the AI, review AI-generated client communications before sending, and supervise non-lawyer staff who use AI. Notes: The newest of the 141 formal opinions in the bar's Office of General Counsel index (the prior newest was 2023-01), applying to every Alabama lawyer regardless of firm size. The opinion document itself is undated (year precision only; the PDF asset path suggests mid-2026 publication but is not citable). Full PDF: https://www.alabar.org/assets/2026/05/FO-2026-01.pdf . Its cautionary examples cite Mata v. Avianca, Ibach v. Stewart (Ala. April 24, 2026), and Johnson v. Dunn (N.D. Ala. 2025). Bot-blocked to automated fetch; read in a live browser session on July 19, 2026. ### Ethics Opinion 2025-1: Generative Artificial Intelligence and the Practice of Law - Jurisdiction: Alaska Bar Association - Type: formal_opinion - Date: 2025-04-23 (precision: day) - Status: current - Key duties: competence, confidentiality, supervision, candor, verification - Primary source: https://alaskabar.org/wp-content/uploads/2025-1.pdf - Last verified: 2026-06-10 - Tracker id: alaska-2025-1 Adopted by the Alaska Bar Board of Governors on April 23, 2025 after Ethics Committee approval on April 3, 2025. Alaska lawyers may use generative AI consistent with existing duties of competence, confidentiality, supervision, and candor, with verification of AI output before use. Notes: Frequently missing from other trackers. ### Generative AI: Ethical Best Practices for Lawyers and Judges - Jurisdiction: Arizona Supreme Court Steering Committee on AI and the Courts - Type: guidance - Date: 2024-11-14 (precision: day) - Status: current - Key duties: competence, diligence, confidentiality, communication, fees, candor, supervision - Primary source: https://www.azbar.org/media/e4chgf0g/aisc-ethical-best-practices-guidance_for-publication.pdf - Last verified: 2026-06-10 - Tracker id: arizona-aisc-best-practices Issued by the court-created AISC steering committee (Administrative Order 2024-33) and published via the State Bar of Arizona, not by a bar ethics committee. Covers seven areas: competence and diligence (check every material proposition and source), confidentiality (no client or nonpublic data into tools without sufficient guarantees, informed consent otherwise), client and supervisor communication (disclose chatbots; no duty to flag every AI use), billing (no charging for time saved; advance written disclosure of AI costs), court disclosure and candor, bias mitigation, and supervision via written, acknowledged firm AI policies. ### Arkansas Supreme Court Administrative Order No. 25: Artificial Intelligence (adopted, 2025 Ark. 220) - Jurisdiction: Arkansas Supreme Court - Type: court_rule - Date: 2025-12-11 (precision: day) - Status: current - Key duties: confidentiality, data protection, accountability - Primary source: https://opinions.arcourts.gov/ark/supremecourt/en/item/524043/index.do - Last verified: 2026-07-19 - Tracker id: arkansas-ao-25-proposed An administrative order the Arkansas Supreme Court adopted by per curiam order on December 11, 2025, effective immediately, after publishing it for comment on June 5, 2025 (2025 Ark. 117) and receiving no substantive comments. Section 1 warns everyone participating in the court system, attorneys included, that generative AI tools may retain input data, distinguishes public from private large language models, and states that entering confidential or sealed client or case information into generative AI may violate Administrative Order 19, Arkansas statutes limiting access to court records, the Arkansas Rules of Professional Conduct, the Code of Judicial Conduct, and applicable rules of procedure. Section 2 prohibits Administrative Office of the Courts staff, clerks of court and their staff, and anyone with access to internal CourtConnect from intentionally exposing the state courts' internal data to generative AI using a public LLM, with research-and-analysis exceptions routed through the Supreme Court's Automation Committee and the CIS Division. Notes: Adopted December 11, 2025, by In re Adoption of Arkansas Supreme Court Administrative Order No. 25 Artificial Intelligence, 2025 Ark. 220 (per curiam), effective immediately; confirmed present in the court's current Administrative Orders compilation (rule current to January 29, 2026, HISTORY line 'Adopted December 11, 2025'). Scope note: the binding Section 2 prohibition is court-staff and court-system facing; Section 1 imposes awareness duties on everyone entering client or court data, attorneys included, with express cross-references to the ARPC. Companion ARPC amendment adopted the same day (2025 Ark. 221). Proposal history: published for comment June 5, 2025 (2025 Ark. 117); comment period closed August 1, 2025. ### Amendments to the Arkansas Rules of Professional Conduct: Preamble paragraph 22 and Rule 5.3 (adopted, 2025 Ark. 221) - Jurisdiction: Arkansas Supreme Court - Type: court_rule - Date: 2025-12-11 (precision: day) - Status: current - Key duties: accountability, supervision, competence - Primary source: https://opinions.arcourts.gov/ark/supremecourt/en/item/524044/index.do - Last verified: 2026-07-19 - Tracker id: arkansas-rpc-amendments-proposed Companion amendment to Administrative Order No. 25, adopted by per curiam order on December 11, 2025, effective immediately, after publication for comment on June 5, 2025 (2025 Ark. 115). It adds paragraph 22 to the Preamble of the Arkansas Rules of Professional Conduct: nothing in the rules prohibits an attorney's use of non-human assistance, including artificial intelligence, but the use of non-human assistance does not excuse or mitigate any violation of the rules, and lawyers are advised to consult Administrative Order No. 25 before using AI. It also changes the heading of Rule 5.3 from Nonlawyer Assistants to Nonlawyer Assistance, with conforming text changes. Notes: Adopted December 11, 2025, by In re Amendments to the Arkansas Rules of Professional Conduct, 2025 Ark. 221 (per curiam), effective immediately, with the amendments shown in line-in, line-out form. Compilation lag caution: the court's posted [Current] ARPC compilation still showed 'Rule Current To 06/12/2025' when checked on July 19, 2026; cite the adoption per curiam for current status, not the lagging compilation. Proposal history: published for comment June 5, 2025 (2025 Ark. 115), on the unanimous recommendation of the Arkansas Bar Association's AI Task Force; comment period closed August 1, 2025. ### Practical Guidance for the Use of Generative Artificial Intelligence in the Practice of Law - Jurisdiction: State Bar of California (COPRAC) - Type: guidance - Date: 2023-11-16 (precision: day) - Status: current - Key duties: competence, confidentiality, verification, fees, supervision, communication - Primary source: https://www.calbar.ca.gov/Portals/0/documents/ethics/Generative-AI-Practical-Guidance.pdf - Last verified: 2026-07-01 - Tracker id: california-practical-guidance The first state guidance in the country, issued November 16, 2023 by the State Bar of California's Standing Committee on Professional Responsibility and Conduct. Chart-format guiding principles: do not input confidential client information into tools lacking adequate security (anonymize inputs; obtain informed consent where risks remain), review and verify all AI outputs before use or filing, bill hourly clients only for time actually spent, and supervise and train lawyers and nonlawyers on AI use. Notes: The PDF now hosted at calbar.ca.gov is a 2026 revision that replaces the 2023 version and adds agentic-AI duties, issued at the California Supreme Court's request. The Board of Trustees approved the updated revisions on May 14, 2026, as stated on the State Bar's Ethics & Technology Resources page (day precision verified 2026-07-01). ### Proposed Amendments to the Rules of Professional Conduct Related to Artificial Intelligence - Jurisdiction: State Bar of California (COPRAC) - Type: proposed - Date: 2026-03-13 (precision: day) - Status: proposed - Key duties: competence, communication, confidentiality, candor, supervision - Primary source: https://www.calbar.ca.gov/public/public-meetings-comment/public-comment/public-comment-archives/2026-public-comment/proposed-amendments-rules-professional-conduct-related-artificial-intelligence - Last verified: 2026-06-10 - Tracker id: california-proposed-rule-amendments Proposed amendments to California Rules of Professional Conduct 1.1 (competence, including AI-output verification), 1.4 (communication), 1.6 (confidentiality), 3.3 (candor), and 5.1 and 5.3 (supervision), approved for public comment by COPRAC on March 13, 2026. The 45-day comment period closed May 4, 2026. If adopted, these would be the first binding state disciplinary rules written specifically for AI. Not adopted as of June 10, 2026. Notes: Follows an August 22, 2025 California Supreme Court directive to consider converting the 2023 guidance into binding rules. Watch for Board of Trustees and Supreme Court action. ### SB 574: Attorneys, arbitrators, judicial officers, and alternative resolution providers (2025-2026) - Jurisdiction: California Legislature - Type: proposed - Date: 2026-07-02 (precision: day) - Status: proposed - Key duties: confidentiality, data protection, accountability, candor - Primary source: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260SB574 - Last verified: 2026-07-19 - Tracker id: california-sb-574 Pending legislation by Senator Umberg that would write attorney generative-AI duties into statute: a new Business and Professions Code section 6068.1 providing that an attorney shall not delegate the practice of law to generative AI and imposing duties on attorneys who use it, including not entering confidential, personal identifying, or other nonpublic information into a public generative AI system; an amendment to Code of Civil Procedure section 128.7, California's filing-certification and sanctions statute; a new section 180 requiring judicial officers in civil and criminal matters to disclose whether anyone involved in researching or drafting a ruling relied on generative AI; and a new section 1282.1 making arbitrators responsible for all aspects of an award regardless of any generative AI use, with disclosure duties. The bill passed the Senate and, as amended July 2, 2026, is in Assembly floor process after a 15-0 do-pass from the Assembly Privacy and Consumer Protection Committee on July 1, 2026. Notes: Date is the July 2, 2026 Assembly amendment (the version read); introduced February 20, 2025. Verified against the bill text and status on leginfo.legislature.ca.gov on July 19, 2026: house location Assembly, active bill in floor process. Pending legislation, not law; distinct from the State Bar's COPRAC practical guidance and proposed rule amendments, which proceed on a separate track. ### Rule Change 2026(02): Colorado Rules of Professional Conduct (Preamble and Scope paragraph [20A]; Rule 1.1 comments [8] and [9]) - Jurisdiction: Colorado Supreme Court - Type: court_rule - Date: 2026-01-08 (precision: day) - Status: current - Key duties: competence, accountability, independent judgment - Primary source: https://www.coloradojudicial.gov/sites/default/files/2026-01/Rule%20Change%202026(02).pdf - Last verified: 2026-07-01 - Tracker id: colorado-rule-change-2026-02 Adopted en banc by the Colorado Supreme Court on January 8, 2026 and effective immediately, this rule change writes AI into the conduct rules. New Preamble and Scope paragraph [20A] provides that technology, including artificial intelligence, does not diminish a lawyer's responsibilities, and that lawyers who use technology directly or indirectly in delivering legal services may be disciplined for resulting violations. Rule 1.1 comment [8] on technological competence is amended, and a new comment [9] catalogs the rules AI use can implicate, Rules 1.4, 1.5, 1.6, 3.1, 3.3, 5.1 through 5.3, 7.1, and 8.4(g), adding that reliance on technology does not diminish the lawyer's independent judgment. Notes: The first AI-specific amendment to a state's Rules of Professional Conduct adopted by a state supreme court that is recorded in this tracker. Colorado also launched a Legal Technology Advisory Committee on September 15, 2025, with initial recommendations due October 1, 2026. ### Ethics Opinion 388: Attorneys' Use of Generative Artificial Intelligence in Client Matters - Jurisdiction: District of Columbia Bar - Type: formal_opinion - Date: 2024-04 (precision: month) - Status: current - Key duties: competence, confidentiality, candor, fees, supervision, client file - Primary source: https://www.dcbar.org/for-lawyers/legal-ethics/ethics-opinions-210-present/ethics-opinion-388 - Last verified: 2026-06-10 - Tracker id: dc-ethics-opinion-388 Technology does not alter fundamental duties. Competence requires understanding that generative AI predicts text and can hallucinate, so outputs must be reviewed and validated. Lawyers must determine whether a tool exposes inputs to third parties or trains on them before entering client confidences, bill hourly clients only for time actually spent, preserve relevant AI interactions in the client file, and supervise others' AI use. Notes: The D.C. Bar publishes the month only (April 2024); no day is given. ### Florida Bar Ethics Opinion 24-1 - Jurisdiction: The Florida Bar - Type: formal_opinion - Date: 2024-01-19 (precision: day) - Status: current - Key duties: confidentiality, consent, supervision, verification, fees, advertising - Primary source: https://www.floridabar.org/etopinions/opinion-24-1/ - Last verified: 2026-06-10 - Tracker id: florida-24-1 Florida lawyers may use generative AI if they protect client confidentiality (informed consent is recommended before feeding confidential information to third-party AI), supervise and verify AI output the way they would a nonlawyer assistant's work, avoid improper billing (no double-billing and no charging clients to learn the tool), and follow advertising rules, including that AI chatbots must disclose they are not a lawyer. Notes: The opinion's face date is January 19, 2024. A January 24 date sometimes cited is the web page's modification date, not the opinion date. ### Amendment to Rule of General Practice and Judicial Administration 2.515(d)(2) (accuracy of cited authorities) - Jurisdiction: Supreme Court of Florida - Type: court_rule - Date: 2026-06-15 (precision: day) - Status: current - Key duties: candor, verification, accountability - Primary source: https://www.floridabar.org/the-florida-bar-news/supreme-court-amends-rules-to-address-ai-use-in-court-filings/ - Last verified: 2026-06-13 - Tracker id: florida-rule-2-515-ai Adopted by the Florida Supreme Court on its own motion (Case No. SC2026-0673, approved May 28, 2026), this amendment provides that by signing a filing, the signer represents that the legal authorities identified exist and are accurately cited. It is an accuracy-of-authorities certification rather than an AI-disclosure rule, and it expressly authorizes sanctions (reprimand, contempt, striking the document, dismissal, costs, or attorneys' fees) after notice and an opportunity to be heard. A companion administrative order preempts circuit-level AI certification requirements to create one statewide standard. Notes: Effective June 15, 2026 at 12:01 a.m. Adopted without prior publication; comments accepted until August 11, 2026. Primary opinion at flcourts-media.flcourts.gov (Case No. SC2026-0673). ### Rules Suggestion 26-CV-21: proposed FRCP 11(a) certification that cited legal authorities exist - Jurisdiction: Judicial Conference Advisory Committee on Civil Rules (federal) - Type: proposed - Date: 2026-05-29 (precision: day) - Status: proposed - Key duties: candor, verification, accountability - Primary source: https://www.uscourts.gov/forms-rules/records-rules-committees/suggestions/hon-patricia-barksdale-26-cv-21 - Last verified: 2026-07-01 - Tracker id: frcp-rule-11-suggestion-26-cv-21 A rules suggestion submitted May 29, 2026 by U.S. Magistrate Judge Patricia Barksdale (M.D. Fla.) asking the Advisory Committee on Civil Rules to add a fifth certification to Federal Rule of Civil Procedure 11(a): that the legal authorities exist and are accurately cited. The suggestion is expressly modeled on the Florida Supreme Court's 2026 amendment to Rule 2.515 and aims to address generative AI use and preempt the growing patchwork of judge-specific standing orders. Docketed with status listed as pending consideration. Notes: Earliest stage of federal rulemaking: a docketed suggestion, not a proposed amendment published for public comment. Before any amendment could take effect it would still need advisory committee action, publication for comment, and approval by the Standing Committee, the Judicial Conference, the Supreme Court, and Congress. Suggestion PDF: uscourts.gov/sites/default/files/document/26-cv-21_suggestion_from_patricia_barksdale_rule_11.pdf. ### Generative AI Toolkit - Jurisdiction: State Bar of Georgia (Special Committee on Artificial Intelligence and Technology) - Type: guidance - Date: 2026-02-20 (precision: day) - Status: current - Key duties: competence, communication, fees, confidentiality, vendor vetting, conflicts, candor, verification, supervision - Primary source: https://www.gabar.org/docs/default-source/lpm/member-resources/generative-ai-toolkit.pdf?sfvrsn=eebe6817_6 - Last verified: 2026-07-01 - Tracker id: georgia-genai-toolkit Bar-issued practical guidance prepared by the Special Committee's Technological Competence Subcommittee with the Law Practice Management Program and the Office of the General Counsel. Georgia lawyers may use generative AI within the Georgia Rules of Professional Conduct, covered rule by rule: Rule 1.1 competence and oversight; Rules 1.4 and 1.5 on fees and informed consent; Rules 1.6, 1.9, and 1.18 on confidentiality and vendor vetting; Rules 1.7, 1.9, and 1.10 on conflicts from intake tools; Rules 3.1 and 3.3 on candor and hallucination verification; and Rules 5.1 and 5.3 on supervision, plus a risk checklist. Expressly not intended to promote or establish a formal advisory opinion; a living document. Notes: Dated February 20, 2026, the Last Updated date stated on the primary PDF. Reported first launched November 2025, but that report is secondary and unconfirmed, so the date is anchored to the primary's own Last Updated line instead. ### Committee on Artificial Intelligence and the Courts: Final Report to the Hawaii Supreme Court (SCMF-24-0000305) - Jurisdiction: Committee on Artificial Intelligence and the Courts (Hawaii Judiciary) - Type: report - Date: 2025-12-15 (precision: day) - Status: current - Key duties: competence, tool vetting, education - Primary source: https://www.courts.state.hi.us/wp-content/uploads/2025/12/121625_SCMF-24-305_CommitteeOnArtificialIntelligenceAndTheCourts_FinalReport.pdf - Last verified: 2026-07-01 - Tracker id: hawaii-ai-courts-report Final report of the committee Chief Justice Mark E. Recktenwald established on April 16, 2024, co-chaired by Associate Justice Vladimir P. Devens and Judge John M. Tonaki. Its Ethics Subcommittee concludes that existing rules, including the Hawaii Rules of Professional Conduct, are broad enough to cover generative AI, so the report proposes no rule changes, an explicit wait-and-see position. It recommends education across CLE, law school AI ethics, and judicial education, a standing judiciary committee to vet AI tools, and continuation of the committee, and it surveys the judiciary's own AI use, including the KolokoloChat chatbot and the internal AI guardrails collected in Appendix 3. Notes: Report date December 15, 2025; e-filed December 16, 2025. A judiciary report, not a bar opinion: the Disciplinary Board's formal-opinions index, inspected July 1, 2026, lists no AI opinion. ### Illinois Supreme Court Policy on Artificial Intelligence - Jurisdiction: Illinois Supreme Court - Type: court_rule - Date: 2024-12-18 (precision: day) - Status: current - Key duties: accountability, verification, confidentiality - Primary source: https://www.illinoiscourts.gov/News/1485/Illinois-Supreme-Court-Announces-Policy-on-Artificial-Intelligence/news-detail/ - Last verified: 2026-06-10 - Tracker id: il-supreme-court-ai-policy A judicial-branch policy authorizing AI use by attorneys, judges, litigants, and court staff provided it complies with legal and ethical standards. The court found existing rules sufficient, declined to require AI disclosure in pleadings, and made users fully accountable for their final work product, including thorough review of AI-generated content before filing and protection of confidential information. Notes: Date shown is the announcement date; the policy was reported effective January 1, 2025. Illinois has no state bar formal ethics opinion on generative AI as of June 2026. ### The Illinois Attorney's Guide to Implementing AI - Jurisdiction: Illinois Attorney Registration and Disciplinary Commission (ARDC) - Type: guidance - Date: 2025-10-24 (precision: day) - Status: current - Key duties: competence, confidentiality, supervision, accountability, communication - Primary source: https://iardc.org/Files/Implementing-AI-Guide/ - Last verified: 2026-06-13 - Tracker id: illinois-ardc-implementing-ai-guide An official ARDC guide, developed in alignment with the Illinois Supreme Court's Policy on Artificial Intelligence, that helps lawyers apply their existing ethical duties when using generative AI. It sets out a three-step framework: classify the sensitivity of the information being processed, identify the type of AI tool (third-party versus internally hosted), and evaluate safeguards such as model-training settings, data retention, isolation, and vendor terms. It includes a Practice Resource Kit with sample policies, checklists, and client-communication templates, aimed especially at solo and small-firm practitioners. Notes: Guidance, not a formal ethics opinion; complements the Illinois Supreme Court AI policy already tracked. Released October 24, 2025 (ISBA announcement at isba.org/barnews/2025/10). ### Ethics Opinion KBA E-457: The Ethical Use of Artificial Intelligence in the Practice of Law - Jurisdiction: Kentucky Bar Association - Type: formal_opinion - Date: 2024-03-15 (precision: day) - Status: current - Key duties: competence, communication, fees, confidentiality, candor, supervision - Primary source: https://kybar.org/Portals/0/Admin/Ethics%20Opinions/KBA%20E-457.pdf - Last verified: 2026-06-10 - Tracker id: kentucky-e-457 A seven-question opinion adopted by the KBA Board of Governors. Lawyers must keep abreast of AI (declining to use available tools may itself implicate competence), need not disclose routine AI research unless work is outsourced, the client is charged, or court rules require it, and must reduce fees when AI shrinks time actually spent. AI expenses are chargeable only with advance written client agreement. Lawyers must safeguard confidences, verify court submissions, and adopt firm AI policies and training. ### Letter re 'The Emergence of Artificial Intelligence' from the Louisiana Supreme Court to the Louisiana State Bar Association - Jurisdiction: Louisiana Supreme Court - Type: guidance - Date: 2024-01-22 (precision: day) - Status: current - Key duties: competence, diligence, communication, confidentiality, candor, accountability, supervision - Primary source: https://www.lsba.org/documents/News/LSBANews/LASCLetterAI.pdf - Last verified: 2026-07-01 - Tracker id: louisiana-supreme-court-ai-letter A letter on Louisiana Supreme Court letterhead, written by General Counsel David Becker expressly at the Justices' direction, copied to all Justices, and sent with a request that the LSBA share it with members. It concludes that Louisiana's existing bench and bar rules are 'robust and broad enough to cover the landscape of issues presented by AI in its current forms,' so no amendments are needed. Attorneys remain responsible for their work product and pleadings, technological competence, confidentiality, and avoiding misrepresentations, with citations to Rules of Professional Conduct 1.1, 1.3, 1.4, 1.6, 1.15, 3.1, 3.3, and 5.3 and to Louisiana Code of Civil Procedure articles 371 and 863. The Court commits to monitoring AI through its Technology Commission and Rules Committee. Notes: LSBA announcement: https://www.lsba.org/NewsArticle.aspx?Article=12b5093a-13ba-407c-b7d9-30057c968c5a . Guidance by letter, not a numbered opinion; the LSBA itself had issued no AI ethics opinion as of July 1, 2026 (its 2019 opinion 19-RPCC-021 on technology due diligence predates generative AI). The Court's Technology Commission later issued judge-facing generative-AI guidelines (October 3, 2025), excluded from this dataset as bench-facing. ### The Wild West of Artificial Intelligence (bar counsel practice article) - Jurisdiction: Massachusetts Board of Bar Overseers (Office of Bar Counsel) - Type: guidance - Date: 2024 (precision: year) - Status: informal - Key duties: competence, confidentiality, supervision, oversight - Primary source: https://bbopublic.massbbo.org/web/f/The_Wild_West_of_Artificial_Intelligence.pdf - Last verified: 2026-06-10 - Tracker id: massachusetts-bbo-article Massachusetts regulates through education rather than opinion. This bar counsel white paper applies Massachusetts Rules 1.1, 1.6, 5.1, and 5.3 to AI: maintain oversight and control of tools, ensure confidentiality protections before use, and supervise AI use firm-wide. Massachusetts courts have sanctioned AI hallucinations (Smith v. Farwell, February 2024). Notes: No formal Massachusetts ethics opinion on generative AI exists as of June 2026. ### Artificial Intelligence for Attorneys: Frequently Asked Questions - Jurisdiction: State Bar of Michigan - Type: guidance - Date: 2024-11-18 (precision: day) - Status: current - Key duties: competence, verification, confidentiality, consent, communication, fees, supervision - Primary source: https://www.michbar.org/opinions/ethics/AIFAQs - Last verified: 2026-06-10 - Tracker id: michigan-ai-faqs Explicitly neither legal advice nor an ethics opinion, the FAQs apply Michigan Rules 1.1 through 8.4 to AI. Lawyers are responsible for all AI-generated content and must verify citations, must obtain client consent under MRPC 1.6(c)(1) before inputting protected information, and have no general duty to tell clients or courts about AI use absent rule triggers. Only actual time spent may be billed; AI subscriptions are normally overhead; matter-specific per-use AI costs are chargeable only by advance agreement. Notes: Fee questions added February 11, 2025. Michigan also has judicial ethics opinion JI-155 (2023) on judges' AI competence. No lawyer-facing formal opinion exists. ### MSBA AI Working Group Final Report: Implications of Large Language Models on UPL and Access to Justice - Jurisdiction: Minnesota State Bar Association - Type: report - Date: 2024-06 (precision: month) - Status: current - Key duties: verification, confidentiality, supervision, UPL - Primary source: https://www.mnbar.org/docs/default-source/default-document-library/msba-ai-working-group-final-report-and-recommendations.pdf - Last verified: 2026-06-10 - Tracker id: minnesota-msba-report Adopted by the MSBA Assembly in summer 2024, this report centers on unauthorized-practice and access-to-justice questions rather than the conduct rules. It recommends an AI regulatory sandbox so nonprofits can deploy LLMs to close the justice gap without UPL exposure, plus a standing MSBA AI committee. It notes existing rules already require accurate outputs, confidentiality-preserving tools, and supervised delegation. ### Ethics Opinion No. 267 - Jurisdiction: The Mississippi Bar - Type: formal_opinion - Date: 2024-11-14 (precision: day) - Status: current - Key duties: confidentiality, verification, fees, consent - Primary source: https://www.msbar.org/ethics-discipline/ethics-opinions/formal-opinions/267/ - Last verified: 2026-06-10 - Tracker id: mississippi-267 Mississippi lawyers may ethically use generative AI with safeguards: an affirmative duty to protect confidentiality under Rule 1.6, a duty to verify the accuracy of AI work (expressly adopting ABA Formal Opinion 512's trust-but-verify analysis), reasonable billing (efficiency gains go to the client; learning time is overhead), and informed client consent in certain situations under Rule 1.4. ### AI Tools for Lawyers: A Practical Guide - Jurisdiction: The Mississippi Bar (Law Practice Management and Technology Committee) - Type: guidance - Date: 2025-07-01 (precision: day) - Status: current - Key duties: competence - Primary source: https://www.msbar.org/media/jgagwizj/ai-practical-guide-7125.pdf - Last verified: 2026-06-10 - Tracker id: mississippi-practical-guide A practitioner-oriented guide surveying AI tools by category (case management, e-discovery, research, contract analysis, and more), with a short ethics section that defers to Ethics Opinion No. 267. A committee publication, not an ethics opinion, and explicitly not an endorsement of any tool. Notes: A separate item from Ethics Opinion 267, issued roughly eight months later. ### Informal Opinion 2024-11 - Jurisdiction: Missouri Office of Legal Ethics Counsel - Type: guidance - Date: 2024-04-25 (precision: day) - Status: current - Key duties: competence, confidentiality, verification, professional independence, supervision, fees - Primary source: https://mo-legal-ethics.org/informal-opinion/2024-11/ - Last verified: 2026-06-10 - Tracker id: missouri-2024-11 An official informal advisory opinion under Missouri Supreme Court Rule 5.30(c), responding to a lawyer designing a firm AI-use policy. Get training before adopting tools, assess platform terms and security before inputting client information, verify AI-assisted content like nonlawyer work, preserve independent professional judgment, and consider fee reasonableness. Firms should build an ethical framework and train both lawyers and nonlawyers. ### Thirteenth Judicial District (Yellowstone County) Local Rules of Practice, Rule 35: Artificial Intelligence - Jurisdiction: Montana Thirteenth Judicial District Court - Type: court_rule - Date: 2026-01-01 (precision: day) - Status: current - Key duties: disclosure, verification, accountability - Primary source: https://www.yellowstonecountymt.gov/clerk_court/LocalRules.pdf - Last verified: 2026-07-01 - Tracker id: montana-13th-district-rule-35 A local rule of Montana's Thirteenth Judicial District (Yellowstone County), adopted by the full ten-judge court over Chief Judge Thomas Pardy's signature and effective January 1, 2026. Any attorney or self-represented party who used generative artificial intelligence in preparing a filed document must identify the type of AI used and certify that every citation to the law or to the record in the document has been verified. Notes: LOCAL rule: Yellowstone County only. Adopted and effective the same day. Montana has no statewide AI instrument; with Fourth Judicial District Rule 3.G, one of the first two district-level local rules recorded in this tracker. ### Fourth Judicial District (Missoula & Mineral Counties) Rules of Practice, Rule 3.G: Pleading Requirements for Use of Generative Artificial Intelligence - Jurisdiction: Montana Fourth Judicial District Court - Type: court_rule - Date: 2025-10-31 (precision: day) - Status: current - Key duties: disclosure, verification, candor, accountability - Primary source: https://courts.mt.gov/external/dcourt/dc_rules/4th.pdf - Last verified: 2026-07-01 - Tracker id: montana-4th-district-rule-3g A district-wide local rule of Montana's Fourth Judicial District (Missoula and Mineral Counties), carried in the October 31, 2025 revision of the district's Rules of Practice. Any party using generative AI in a filing must disclose the use, identify the specific tool, and explain how it was used, and must certify that the accuracy of all AI-drafted or AI-assisted portions has been checked. A filing submitted without the certification presumptively certifies that no generative AI was used. Responsibility is anchored in Rule 11 and the rules of professional conduct, with sanctions available up to dismissal without prejudice. Notes: LOCAL rule: Missoula and Mineral Counties only, adopted district-wide rather than as an individual judge's standing order. Date shown is the Rules of Practice revision date. Montana has no statewide AI instrument; with Thirteenth Judicial District Rule 35, one of the first two district-level local rules recorded in this tracker. ### Understanding Generative Artificial Intelligence and The Potential for Discrimination and Bias - Jurisdiction: New Hampshire Bar Association Ethics Committee - Type: guidance - Date: 2024-10-30 (precision: day) - Status: current - Key duties: competence, bias monitoring, independent judgment - Primary source: https://www.nhbar.org/understanding-generative-artificial-intelligence-and-the-potential-for-discrimination-and-bias/ - Last verified: 2026-07-01 - Tracker id: new-hampshire-ethics-ai-bias The third NHBA Ethics Committee Ethics Corner article on generative AI, reviewed by the Board of Governors on October 24, 2024 and published October 30, 2024. Rule 1.1 competence includes understanding algorithmic bias and the potential for discrimination in generative AI output. Inadvertent AI-introduced bias is not by itself a Rule 8.4(g) violation, which requires purpose or animus, but Rule 2.1 requires lawyers to critically evaluate AI output rather than accept it. The article commends ABA Formal Opinion 512. Notes: Third in the three-article series; guidance, not a formal opinion. An NHBA Special Committee on AI, chaired by President-Elect Bob Lucic, was developing further guidance as of July 1, 2026. ### Ethics of Drafting Documents with Artificial Intelligence - Jurisdiction: New Hampshire Bar Association Ethics Committee - Type: guidance - Date: 2024-09-10 (precision: day) - Status: current - Key duties: communication, consent, confidentiality, verification, supervision, fees - Primary source: https://www.nhbar.org/drafting-documents-with-artificial-intelligence/ - Last verified: 2026-07-01 - Tracker id: new-hampshire-ethics-ai-drafting The second NHBA Ethics Committee Ethics Corner article on generative AI, reviewed by the Board of Governors on June 7, 2024 and published September 10, 2024. Drafting documents with outside generative AI is permissible only with caveats: Rule 1.4 requires consulting the client and Rule 1.6 requires informed consent before client information is disclosed to an outside AI tool, and the committee counsels avoiding outside generative AI for pleadings. Everything drafted must be verified under Rules 1.1 and 3.3, supervision under Rules 5.1 through 5.3 extends to nonhuman assistance, generic drafting uses remain permissible, and the article flags a possible future Rule 1.5 duty to use cost-reducing technology. Notes: Second in the three-article series; guidance, not a formal opinion. ### Ethics of Using Artificial Intelligence in Practice - Jurisdiction: New Hampshire Bar Association Ethics Committee - Type: guidance - Date: 2024-05-15 (precision: day) - Status: current - Key duties: competence, verification, candor, confidentiality, supervision, independent judgment - Primary source: https://www.nhbar.org/using-artificial-intelligence-in-practice/ - Last verified: 2026-07-01 - Tracker id: new-hampshire-ethics-ai-practice The first of the NHBA Ethics Committee's three Ethics Corner articles on generative AI, submitted to the Board of Governors on February 8, 2024 and published May 15, 2024. Lawyers have no duty to adopt AI, but Rule 1.1 technological competence governs those who do. Outputs must be vetted before use, with Mata v. Avianca as the warning example; unvetted output risks Rules 3.3, 3.4, 4.1, and 8.4(c). Rule 1.6 controls how client data is handled by AI tools, Rules 5.1 and 5.3 extend supervision to AI use across a firm, Rule 2.1 preserves independent professional judgment, and firms should adopt safeguards and policies. Notes: A bar-committee practical-ethics article reviewed by the Board of Governors, not a formal ethics opinion: New Hampshire had no formal NHBA AI opinion and no judiciary AI order as of July 1, 2026. First in a three-article series; see the companion drafting and bias entries. ### Formal Ethics Advisory Opinion 2024-004: Using Generative Artificial Intelligence in the Practice of Law - Jurisdiction: State Bar of New Mexico - Type: formal_opinion - Date: 2024-09-24 (precision: day) - Status: current - Key duties: competence, confidentiality, verification, conflicts, supervision, communication, fees - Primary source: https://www.sbnm.org/Portals/NMBAR/GenAI%20Formal%20Opinion%20-%20Sept_2024_FINAL.pdf - Last verified: 2026-06-10 - Tracker id: new-mexico-2024-004 Lawyers may use generative AI, but must understand each tool's data handling, never input confidential or identity-revealing information into tools lacking protections, anonymize client details, and independently verify all research, citations, and analysis through traditional databases before filing, not by asking the same AI. It also flags former-client conflicts from self-learning tools, requires firm AI policies and training, and lists triggers for discussing AI use with clients. ### Circuit Advisory Committee Note to Ninth Circuit Rule 32-1 (signature attestation and generative AI) - Jurisdiction: U.S. Court of Appeals for the Ninth Circuit - Type: guidance - Date: 2025-12-01 (precision: day) - Status: current - Key duties: verification, accountability, candor - Primary source: https://cdn.ca9.uscourts.gov/datastore/uploads/rules/ALL+CR+Revisions+FINAL+Sept+2025.pdf - Last verified: 2026-07-01 - Tracker id: ninth-circuit-rule-32-1-note Official commentary adopted with the Ninth Circuit's December 1, 2025 circuit-rule revisions. The note states that the rules do not directly regulate the process by which a party or an attorney produces a filing, whether written personally, delegated to a subordinate, or prepared with generative artificial intelligence; regardless of how a filing is prepared, the signature required by FRAP 32(d) is an attestation that the signer has reviewed the filing and is responsible for its contents. Notes: An advisory committee note interpreting the existing FRAP 32(d) signature requirement, not a new binding rule. The court's rules page lists the December 2025 revisions as incorporated in the rules handbook effective June 1, 2026 (inferred from the rules page; handbook PDF not separately fetched). Quoted and applied in the published sanctions order Lnu v. Blanche, No. 24-4790 (9th Cir. June 3, 2026), which suspended two attorneys for six months and fined each $2,500 over AI-hallucinated citations and lack of candor. ### Preliminary Guidelines on New Jersey Lawyers' Use of Artificial Intelligence - Jurisdiction: New Jersey Supreme Court - Type: guidance - Date: 2024-01-24 (precision: day) - Status: current - Key duties: verification, candor, confidentiality, communication, supervision - Primary source: https://www.njcourts.gov/sites/default/files/notices/2024/01/n240125a.pdf - Last verified: 2026-06-10 - Tracker id: nj-preliminary-guidelines Interim guidelines issued by the New Jersey Supreme Court stating that AI changes no duties under the Rules of Professional Conduct. Lawyers must verify all AI-generated information, maintain candor to tribunals (there is no duty to disclose AI use, but no excuse for false content), and ensure a tool's security before entering non-public client information. There is no blanket duty to tell clients about AI use; disclosure is required if the client asks or cannot make an informed decision without knowing. ### 2024 Formal Ethics Opinion 1: Use of Artificial Intelligence in a Law Practice - Jurisdiction: North Carolina State Bar - Type: formal_opinion - Date: 2024-11-01 (precision: day) - Status: current - Key duties: competence, confidentiality, privilege, supervision, fees - Primary source: https://www.ncbar.gov/for-lawyers/ethics-and-governing-rules/ethics-opinions/opinions/2024-formal-ethics-opinion-1/ - Last verified: 2026-06-10 - Tracker id: north-carolina-2024-feo-1 A question-and-answer opinion adopted by the State Bar Council. Lawyers may use AI but retain ultimate responsibility for all work product, must vet confidentiality and privilege implications before feeding client-specific information to third-party AI, and must supervise AI like nonlawyer assistance. On billing, a lawyer cannot charge three hours for a one-hour AI-assisted task, though flat fees or disclosed AI costs with client consent are permissible. ### Public Notice on the Use of Artificial Intelligence (AI) - Jurisdiction: North Dakota Court System - Type: guidance - Date: 2026-06-01 (precision: day) - Status: current - Key duties: accountability, verification, candor, confidentiality, supervision - Primary source: https://www.ndcourts.gov/Media/Default/public-notice/Public-Notice-Regarding-Use-of-AI.pdf - Last verified: 2026-07-01 - Tracker id: north-dakota-court-ai-notice A practitioner-facing public notice from the North Dakota Court System addressed to attorneys, self-represented litigants, and the public about court filings. AI is not prohibited in matters before North Dakota courts, but full responsibility for filings, including AI errors and fabricated citations, rests with the attorney or self-represented litigant. Filings must comply with N.D.R.Civ.P. 11, and courts may strike noncompliant documents and impose sanctions under N.D.R.Ct. 11.5. The notice maps AI use onto N.D.R.Prof.Conduct 1.1 (competence), 3.1 and 3.3 (candor, with personal verification of every cited authority), and 5.1 and 5.3 (supervision), cautions against entering personal identifying information, protected health information, or sealed material into AI tools, imposes no disclosure requirement solely for AI use, and states it is subject to ongoing revision. Notes: Practitioner-facing guidance about filings (attorneys, self-represented litigants, and the public), not a bench or staff use policy. The State Bar Association of North Dakota's ethics-opinions index, inspected July 1, 2026, lists no AI opinion. ### 22 NYCRR Part 161: Use of Artificial Intelligence Technology - Jurisdiction: New York Unified Court System - Type: court_rule - Date: 2026-06-01 (precision: day) - Status: current - Key duties: verification, candor, accountability - Primary source: https://ww2.nycourts.gov/rules/chiefadmin/161.shtml - Last verified: 2026-06-10 - Tracker id: ny-22-nycrr-part-161 A binding, system-wide court rule applying to all New York Unified Court System courts in civil and criminal cases, adopted March 25, 2026 and effective June 1, 2026. It is permissive and accountability-based: attorneys and parties may use AI in preparing court papers, and no system-wide disclosure of AI use is required. Individual courts are encouraged, not required, to adopt the Appendix A model rule, under which signing a paper certifies the signer carefully reviewed it and independently confirmed it contains no fabricated cases, statutes, or other material, with sanctions available under 22 NYCRR 130-1.1 and Rule of Professional Conduct 3.3. Notes: Date shown is the effective date. Papers offered as evidence are excluded. Preceded by the UCS interim AI policy for judges and court staff (October 2025). ### Formal Opinion 2024-5: Ethical Obligations Relating to Generative Artificial Intelligence - Jurisdiction: New York City Bar Association - Type: formal_opinion - Date: 2024-08-07 (precision: day) - Status: current - Key duties: competence, confidentiality, verification, supervision, fees, candor, communication - Primary source: https://www.nycbar.org/reports/formal-opinion-2024-5-generative-ai-in-the-practice-of-law/ - Last verified: 2026-06-10 - Tracker id: nyc-bar-2024-5 Modeled on California's 2023 guidance and framed as guardrails, not new rules. Lawyers must protect confidences before inputting client data (informed consent for open systems), verify outputs and citations (citing Mata v. Avianca and United States v. Cohen), supervise firm-wide AI use, and bill only actual time. Routine embedded AI such as autocomplete or research-platform features does not require disclosure. Notes: Often misdated to April 2024; the opinion is dated August 7, 2024. ### Formal Opinion 2025-6: Ethical Issues Affecting Use of AI to Record, Transcribe, and Summarize Conversations with Clients - Jurisdiction: New York City Bar Association - Type: formal_opinion - Date: 2025-12-22 (precision: day) - Status: current - Key duties: consent, confidentiality, verification, competence - Primary source: https://www.nycbar.org/reports/formal-opinion-2025-6-ethical-issues-affecting-use-of-ai-to-record-transcribe-and-summarize-conversations-with-clients/ - Last verified: 2026-06-10 - Tracker id: nyc-bar-2025-6 Requires informed client consent before using AI to record or transcribe client conversations, vendor vetting under Rule 1.6, accuracy checks of transcripts and summaries, and Rule 1.1 understanding of the tool. One of the first opinions on AI meeting assistants specifically. ### Report and Recommendations of the NYSBA Task Force on Artificial Intelligence - Jurisdiction: New York State Bar Association - Type: report - Date: 2024-04-06 (precision: day) - Status: current - Key duties: competence, confidentiality, supervision, communication, candor - Primary source: https://nysba.org/wp-content/uploads/2022/03/2024-April-Report-and-Recommendations-of-the-Task-Force-on-Artificial-Intelligence.pdf - Last verified: 2026-06-10 - Tracker id: nysba-task-force-report An extensive report adopted by the NYSBA House of Delegates examining the legal, social, and ethical impact of AI, with guidelines keyed to the New York Rules of Professional Conduct. It recommends prioritizing education over new legislation, a standing committee to keep guidelines current, and disclosure to clients of AI use. ### Artificial Intelligence for Lawyers and Judicial Officers — Ohio Ethics Guide - Jurisdiction: Ohio Board of Professional Conduct - Type: guidance - Date: 2026-04 (precision: month) - Status: current - Key duties: competence, communication, fees, confidentiality, independent judgment, candor, supervision - Primary source: https://www.bpc.ohio.gov/_files/ugd/c6a571_bae3fbcec80a4efeb99df928989e6811.pdf - Last verified: 2026-07-01 - Tracker id: ohio-bpc-ai-ethics-guide Nonbinding staff guidance from the Ohio Board of Professional Conduct that expressly does not reflect the views of the Board or the Supreme Court of Ohio. It applies Prof.Cond.R. 1.1, 1.4, 1.5, 1.6, 2.1, 3.1, 3.3, 5.1, and 5.3, plus the Code of Judicial Conduct, to generative AI: professional judgment is not delegable to a tool; all output must be verified before use, citing State v. Coleman, 2026-Ohio-965, where unverified AI work brought a $2,000 sanction and a disciplinary referral; lawyers bill only actual time, so AI efficiency savings inure to the client; client-identifying data stays out of free and public AI tools; and judges never use AI to decide a case or to produce the first draft of a decision. Notes: PDF footer states Published April 2026 (month precision). Carry the framing verbatim: nonbinding staff guidance that expressly does not reflect the views of the Board or the Supreme Court of Ohio. The Board has issued no advisory opinion on AI. ### Rule 1.17, Use of Generative Artificial Intelligence, Rules of the Oklahoma Court of Criminal Appeals (2026 OK CR 7) - Jurisdiction: Oklahoma Court of Criminal Appeals - Type: court_rule - Date: 2026-02-18 (precision: day) - Status: current - Key duties: verification, accountability, candor - Primary source: https://www.okcca.net/cases/2026/OK-CR-7/ - Last verified: 2026-07-01 - Tracker id: oklahoma-occa-rule-1-17 Adopted by order published as 2026 OK CR 7 and effective on the order date, February 18, 2026. When generative artificial intelligence is used in drafting any filing before the Oklahoma Court of Criminal Appeals, the party or counsel must ensure that every AI-produced or AI-modified portion 'has been verified as accurate by a person responsible for the document.' Sanctions for noncompliance include waiver of the affected issues, striking of the document, and contempt. Notes: Scope is filings before the OCCA, Oklahoma's court of last resort for criminal cases, so the rule reaches statewide criminal appellate practice but not civil litigation or the trial courts; the first criminal-appellate AI rule recorded in this tracker. Rule text also at https://www.okcca.net/rules/rule-1.17/ . Presiding Judge Lumpkin specially concurred, writing that a signature on a filing already certifies its accuracy. ### Formal Opinion 2025-205: Artificial Intelligence Tools - Jurisdiction: Oregon State Bar - Type: formal_opinion - Date: 2025-02 (precision: month) - Status: current - Key duties: competence, communication, fees, confidentiality, consent, supervision, verification - Primary source: https://www.osbar.org/_docs/ethics/2025-205.pdf - Last verified: 2026-06-10 - Tracker id: oregon-2025-205 Approved by the Board of Governors in February 2025. Oregon lawyers may use AI with qualifications: ongoing technology competence, client communication and possible disclosure depending on case-specific factors, no charging to learn AI absent client request and clear agreement, a confidentiality analysis distinguishing open from closed AI models (informed consent before putting client information into an open model), supervision and training duties, and mandatory accuracy review of any output containing case-specific facts, citations, quotations, or conclusions. ### Joint Formal Opinion 2024-200: Ethical Issues Regarding the Use of Artificial Intelligence - Jurisdiction: Pennsylvania Bar Association and Philadelphia Bar Association - Type: formal_opinion - Date: 2024-05 (precision: month) - Status: current - Key duties: competence, verification, confidentiality, consent, conflicts, candor, supervision, fees - Primary source: https://www.lawnext.com/wp-content/uploads/2024/06/Joint-Formal-Opinion-2024-200.pdf - Last verified: 2026-06-10 - Tracker id: pa-philadelphia-2024-200 Lawyers may use AI with appropriate safeguards. The opinion sets out twelve best practices: verify every citation and cited material, keep client data out of tools lacking confidentiality protections, communicate AI use to clients and obtain consent where needed, watch for AI-driven conflicts and bias, and ensure AI-related expenses are reasonable and disclosed. Advisory and non-binding on the Disciplinary Board. Notes: The opinion text is undated; May 2024 per contemporaneous coverage. The PBA original sits behind a member login; the public copy is hosted by LawSites. ### In re Amendments to Article V, Rule 1.1 (Professional Conduct) and Adoption of Interim Generative AI Guidelines - Jurisdiction: Rhode Island Supreme Court - Type: court_rule - Date: 2026-06-17 (precision: day) - Status: current - Key duties: competence, verification, fees, confidentiality, communication, reporting misconduct - Primary source: https://www.courts.ri.gov/Miscellaneous%20Orders/Supreme-2026-06_In_reAmendments_Article_V_Rule_1_1_Professional_Conduct.pdf - Last verified: 2026-07-01 - Tracker id: rhode-island-rule-1-1-gai-order An order of the Rhode Island Supreme Court, entered June 17, 2026, with dual character. It amends comment [6] to Article V, Rule 1.1 so that competence includes keeping abreast of the benefits and risks of existing and developing technology, and it adopts the attached advisory Interim Guidelines for the Ethical Use of Generative AI. The lawyer guidelines work rule by rule: verify all generative AI output; bill actual time, with generative AI costs treated as overhead absent client-requested specialty tools; vet a tool's confidentiality terms before use; disclose generative AI use when the client asks or when client information is input; and weigh Rule 8.3 reporting where opposing counsel's generative AI misconduct is substantial. Separate judicial-officer guidelines provide that generative AI must never undermine or replace independent judicial decision-making and that judges 'should never rely on GAI-produced content when drafting' orders or decisions. Notes: Dual character: the comment [6] amendment is a binding conduct-rule change (the Colorado comment-amendment route), while the attached interim guidelines are advisory and expressly without the force of law. Signed by Suttell, C.J., with Robinson, Lynch Prata, and Long, JJ. The court's Ethics Advisory Panel, to which the guidelines direct lawyers, has issued no AI opinion. ### Opinion 705 - Jurisdiction: State Bar of Texas (Professional Ethics Committee) - Type: formal_opinion - Date: 2025-02 (precision: month) - Status: current - Key duties: competence, confidentiality, consent, verification, fees - Primary source: https://www.legalethicstexas.com/resources/opinions/opinion-705/ - Last verified: 2026-06-10 - Tracker id: texas-705 Issued at the request of the State Bar of Texas Taskforce on Responsible AI in the Law as a high-level overview. Lawyers must reasonably understand generative AI before using it, protect confidential information and consider client consent before exposing it to AI, independently verify AI output before relying on it (citing Mata v. Avianca), and bill honestly: AI efficiency gains belong to the client, and lawyers may not bill for hours not worked. ### Using ChatGPT in Our Practices: Ethical Considerations (bar article) - Jurisdiction: Utah State Bar - Type: guidance - Date: 2023-05 (precision: month) - Status: informal - Key duties: consent, confidentiality, fees, verification - Primary source: https://www.utahbar.org/wp-content/uploads/2023/05/ChatGPT-article.pdf - Last verified: 2026-06-10 - Tracker id: utah-bar-article Utah's only AI-specific bar publication is an informal article advising lawyers to let clients decide on ChatGPT use after a risk and benefit explanation, share only non-identifying information with AI, bill only actual time spent, and treat AI output like a law clerk's draft requiring citation checks. The Bar's AI Standing Committee publishes educational content but has issued no opinions. Notes: No formal or advisory Utah ethics opinion on AI exists as of June 2026. ### VJCAIC First Annual Report (lawyer guidance in Appendix G) - Jurisdiction: Vermont Judiciary Committee on Artificial Intelligence and the Courts - Type: report - Date: 2025-03 (precision: month) - Status: current - Key duties: competence, confidentiality, fees, verification, supervision - Primary source: https://www.vermontjudiciary.org/sites/default/files/documents/VJCAIC%20First%20Annual%20Report%20%28final%29.pdf - Last verified: 2026-06-10 - Tracker id: vermont-vjcaic-report Created by the Vermont Supreme Court, the committee concluded no amendments to the conduct rules are warranted because generative AI use falls within existing rules, and issued guidance instead: keep abreast of AI risks and benefits, review tool terms of service and understand how confidential information is used or retained, never bill hourly clients for time saved, confirm output accuracy, and consider an office AI-use policy as part of supervision duties. Notes: A judiciary instrument, not bar guidance. Vermont has no bar ethics opinion on AI. ### Legal Ethics Opinion 1901: Reasonable Fees and the Use of Generative Artificial Intelligence - Jurisdiction: Virginia State Bar (approved by the Supreme Court of Virginia) - Type: formal_opinion - Date: 2025-11-24 (precision: day) - Status: current - Key duties: fees, communication - Primary source: https://www.vacourts.gov/static/courts/scv/amendments/leo_1901.pdf - Last verified: 2026-06-10 - Tracker id: virginia-leo-1901 Virginia's only numbered AI ethics opinion, and unusual nationally for carrying Supreme Court of Virginia approval (effective November 24, 2025). Hourly bills must reflect actual time, but Rule 1.5 does not require proportionate fee reductions when AI speeds work; value-based and alternative fee arrangements may capture AI-driven efficiency. Notes: VSB Council approved June 12, 2025; effective on Supreme Court of Virginia approval November 24, 2025. ### VBA Task Force on Artificial Intelligence: Model AI Policy - Jurisdiction: Virginia Bar Association (voluntary bar) - Type: guidance - Date: 2024 (precision: year) - Status: current - Key duties: tool vetting, training, confidentiality, verification, supervision - Primary source: https://cdn.ymaws.com/www.vba.org/resource/resmgr/home/2024/vba_model_ai_policy.pdf - Last verified: 2026-06-10 - Tracker id: virginia-vba-model-policy A template internal-governance policy for law firms covering AI tool selection and approval, training, data confidentiality, output validation and oversight, and use of AI in decision-making. Issued by the voluntary Virginia Bar Association's AI task force (established April 2024), not by the regulatory Virginia State Bar. Notes: Often conflated with the Virginia State Bar's guidance; they are different bodies. ### Generative AI guidance (VSB Ethics and Conduct page) - Jurisdiction: Virginia State Bar - Type: guidance - Date: 2024 (precision: year) - Status: current - Key duties: competence, confidentiality, verification, supervision, fees - Primary source: https://vsb.org/Site/Site/lawyers/ethics.aspx - Last verified: 2026-06-10 - Tracker id: virginia-vsb-guidance The mandatory Virginia State Bar chose a short website update rather than an opinion: basic ethical responsibilities are unchanged; lawyers must vet AI providers' data handling before exposing confidences; there is no per se requirement to inform a client of generative AI use absent agreement or elevated risk; all output must be reviewed and citations verified, a duty extending to supervising others' AI use; and lawyers may not bill hourly clients for time saved by AI. Notes: Distinct from the voluntary Virginia Bar Association's Model AI Policy (2024) and from LEO 1901. ### WSBA Advisory Opinion 2025-05: Artificial Intelligence-Enabled Tools in Law Practice - Jurisdiction: Washington State Bar Association - Type: formal_opinion - Date: 2025 (precision: year) - Status: current - Key duties: competence, verification, confidentiality, fees, supervision, candor - Primary source: https://www.wsba.org/docs/default-source/legal-community/committees/committee-on-professional-ethics/ao-202505.pdf - Last verified: 2026-06-10 - Tracker id: washington-ao-2025-05 A published advisory opinion of the WSBA Committee on Professional Ethics that deliberately addresses AI broadly: machine-learning, generative, agentic, and future autonomous tools. Lawyers must know tools' capabilities and risks, verify AI work product, protect information shared with tools, bill fairly (no charging for time saved; no overhead pass-through without consent), and supervise firm AI use. Notes: Published 2025 (November per secondary reports; day unverified on the opinion itself). ### Legal Ethics Opinion 24-01: Artificial Intelligence - Jurisdiction: West Virginia Lawyer Disciplinary Board - Type: formal_opinion - Date: 2024-06 (precision: month) - Status: current - Key duties: competence, diligence, written consent, confidentiality, supervision, bias monitoring - Primary source: https://wvodc.org/Legal-Ethics-Opinion - Last verified: 2026-06-10 - Tracker id: west-virginia-leo-24-01 AI may supplement but never replace a lawyer's own reasoning; AI is at best a secondary source. Diligence requires human oversight and intervention to correct AI mistakes. Notably, the opinion requires client consent to generative-AI use that is informed and confirmed in writing, one of the strictest consent positions in the country. Lawyers must vet terms of use and privacy policies, supervise AI like nonlawyer assistance, and monitor tools for errors and bias. Notes: Strictest client-consent position nationally: informed consent confirmed in writing. ### Ethical Dilemma: Ethical Considerations When Using Generative Artificial Intelligence - Jurisdiction: State Bar of Wisconsin (ethics counsel) - Type: guidance - Date: 2024-10-04 (precision: day) - Status: current - Key duties: competence, communication, fees, confidentiality, consent, verification, candor, supervision - Primary source: https://www.wisbar.org/NewsPublications/WisconsinLawyer/Pages/Article.aspx?Volume=97&Issue=9&ArticleID=30672 - Last verified: 2026-07-01 - Tracker id: wisconsin-ethics-counsel-gai The State Bar of Wisconsin's official Ethical Dilemma column in Wisconsin Lawyer, 97 Wis. Law. 29-32, written by State Bar ethics counsel Sarah E. Peterson. Applying SCR 20:1.1, 1.4, 1.5, 1.6, 3.1, 3.3, 8.4(c), and 5.1 and 5.3 through the lens of ABA Formal Opinion 512: generative AI is permitted with technological competence; all output must be independently verified; informed client consent is required before confidential client information enters self-learning tools; a client's instruction not to use generative AI must be honored; only actual time may be billed; and firms should adopt AI policies and training. Notes: Bar-staff educational guidance in the bar's official magazine column (the Massachusetts BBO and NHBA precedent); date is the October 4, 2024 issue date. PDF: https://www.wisbar.org/NewsPublications/WisconsinLawyer/WisconsinLawyerPDFs/97/10/29_32.pdf . No State Bar of Wisconsin formal ethics opinion (EF-series) on AI exists. ### Transitioning to Generative AI? Don't Leave the Rules of Professional Conduct Behind - Jurisdiction: Wyoming State Bar (Bar Counsel) - Type: guidance - Date: 2024-02 (precision: month) - Status: current - Key duties: competence, diligence, verification, confidentiality, fees, supervision, candor - Primary source: https://digitaleditions.walsworth.com/publication/?i=815132&article_id=4723910&view=articleBrowser - Last verified: 2026-07-01 - Tracker id: wyoming-bar-counsel-gai An article by Wyoming State Bar Counsel Mark W. Gifford in Wyoming Lawyer, the bar's official magazine. Generative AI is a starting point, never a finished product, and never a source of citations without verification, grounded in W.R.Prof.Cond. 1.1 comment [6] and Rule 1.3; client-identifying data stays out of generative AI tools under Rule 1.6; hourly clients may not be charged for time generative AI saved, under Rule 1.5; firms need uniform AI policies and training under Rules 5.1 through 5.3; and candor duties under Rules 3.1 and 3.3, plus W.R.Civ.P. 11(b), govern everything filed. Notes: Bar-staff guidance in the bar's official magazine, February 2024 (month precision). The article documents that the Wyoming Judicial Council had circulated no generative-AI rule changes. Wyoming publishes no formal ethics opinions; the Bar Counsel ethics hotline is informal and non-binding. ## Sanctions cases (19) Court sanctions decisions from the generative-AI era, each verified against the court's own published document before listing, with sanction amounts, rule basis, and the AI-attribution status exactly as the primary document states it. Newest row-level verification date: 2026-07-21 ### Davis v. Marion County Superior Court Juvenile Detention Center, No. 1:24-cv-01918 - Court: U.S. District Court for the Southern District of Indiana - Jurisdiction: Federal (S.D. Ind.) - Date: 2026-05-20 (precision: day) - Sanction type: Monetary sanction against counsel personally (the district judge reduced the magistrate's recommended amount and declined the recommended professional-conduct referral) - Amount: $2,000 (against attorney Tae Sture) - Rule basis: Fed. R. Civ. P. 11(b) - AI tool alleged: Unnamed generative AI — court inference only; counsel attributed the citations to Fastcase, and the court made no express finding that AI was used - Verification status: verified-primary - Primary source: https://websitedc.s3.amazonaws.com/documents/Davis_v._Marion_Country_Juvenile_DC_USA_20_May_2026.pdf - Last verified: 2026-07-21 - Tracker id: davis-v-marion-county The court imposed a $2,000 Rule 11 sanction on attorney Tae Sture for fabricated citations it inferred came from generative AI, though counsel claimed the tool was Fastcase. The frequently cited "2025 WL 2502308 (Sept. 2, 2025)" is the magistrate's report recommending $7,500; the district judge later reduced the sanction to $2,000 and rejected the recommended disciplinary referral. ### Doiban v. Oregon Liquor and Cannabis Commission, No. A181982 - Court: Oregon Court of Appeals - Jurisdiction: Oregon (state) - Date: 2026-03-18 (precision: day) - Sanction type: Monetary sanction against counsel, capped below the amount the court's per-infraction formula would produce - Amount: $10,000 (against attorney William L. Ghiorso; capped below the roughly $16,500 that 15 fabricated citations and 9 false quotations would yield under the Ringo formula) - Rule basis: ORCP 17 C(3), via ORAP 1.40(4) - AI tool alleged: Generative AI (via search-engine AI) — counsel's staff relied on search engines including Google, whose AI-generated responses affirmed the nonexistent cases; the court tied the fabrications to generative AI's "tendency to fabricate" and applied its Ringo framework - Verification status: verified-primary - Primary source: https://storage.courtlistener.com/pdf/2026/03/18/doiban_v._olcc.pdf - Last verified: 2026-07-21 - Tracker id: doiban-v-olcc Reported at 347 Or App 742. The largest of the four Oregon appellate AI-fabrication sanctions in this dataset: $10,000 against attorney William L. Ghiorso for at least 15 fabricated citations and 9 false quotations, expressly applying and capping the fee schedule the court originated in Ringo. Decided March 18, 2026 — not December 2025, a date some secondary reports carry over from Ringo. ### Fletcher v. Experian Information Solutions, Inc., No. 25-20086 - Court: U.S. Court of Appeals for the Fifth Circuit - Jurisdiction: Federal (5th Cir.) - Date: 2026-02-18 (precision: day) - Sanction type: Monetary sanction against counsel, payable to the court - Amount: $2,500 (against attorney Heather Hersh) - Rule basis: FRAP 46(c); inherent authority - AI tool alleged: Found (unnamed) — the court found counsel "used artificial generative intelligence to draft a substantial portion — if not all — of her reply brief"; no specific tool named - Verification status: verified-primary - Primary source: https://www.ca5.uscourts.gov/opinions/pub/25/25-20086-CV0.pdf - Last verified: 2026-07-21 - Tracker id: fletcher-v-experian Published order sanctioning attorney Heather Hersh $2,500 after the Fifth Circuit found her reply brief contained unsupported and fabricated citations it attributed to generative AI. Cited by docket and date: the reporter and Westlaw pagination for this opinion were not independently confirmable from free sources. ### Grant v. City of Long Beach, Nos. 22-56121, 22-56143 - Court: U.S. Court of Appeals for the Ninth Circuit - Jurisdiction: Federal (9th Cir.) - Date: 2024-03-22 (precision: day) - Sanction type: Opening brief stricken in its entirety; appeal dismissed - Amount: None (non-monetary) - Rule basis: 9th Cir. R. 28-1 (material failure to comply with briefing rules); FRAP 28(a)(8)(A) - AI tool alleged: None — the published opinion (96 F.4th 1255) never mentions artificial intelligence; it documents fabricated case law and misrepresented authorities without any finding as to their source - Verification status: verified-primary - Primary source: https://cdn.ca9.uscourts.gov/datastore/opinions/2024/03/22/22-56121.pdf - Last verified: 2026-07-19 - Tracker id: grant-v-city-of-long-beach Published opinion (Desai, J., joined by H.A. Thomas, J., and Márquez, D.J.) striking an opening brief "replete with misrepresentations and fabricated case law" and dismissing the appeal. The panel documented two cited cases that "do not appear to exist" and a dozen real cases whose facts and holdings were misrepresented; at oral argument, counsel did not acknowledge the fabrications even when asked directly. The Ninth Circuit's 2026 Lnu order cites Grant as its precedent for striking a brief "composed almost entirely of fabricated or inaccurate citations." Included as a fabricated-citations sanction; the opinion makes no AI finding at all, and the dataset preserves that distinction. ### In re: Sanctions Order of Kerry Kenney, No. 25-C-389 - Court: Louisiana Court of Appeal, Fifth Circuit - Jurisdiction: Louisiana (state) - Date: 2025-10-23 (precision: day) - Sanction type: Monetary sanction payable to defendants; three hours of ethics and AI continuing legal education; referral to the Louisiana Attorney Disciplinary Board - Amount: $1,368 (against attorney Connie P. Trieu) - Rule basis: La. Code Civ. Proc. art. 863(B)(2) & (D) - AI tool alleged: Named — ChatGPT, Microsoft Copilot, and Google Gemini - Verification status: verified-primary - Primary source: https://law.justia.com/cases/louisiana/fifth-circuit-court-of-appeal/2025/25-c-389.html - Last verified: 2026-07-21 - Tracker id: in-re-kenney On supervisory writ, the Louisiana Fifth Circuit affirmed a trial-court sanction (rendered August 11, 2025) of $1,368, three hours of ethics and AI CLE, and a disciplinary referral against attorney Connie P. Trieu for filings citing fabricated authority from ChatGPT, Copilot, and Gemini. Kerry Kenney is the plaintiff, not the sanctioned lawyer. The case is cited by docket because the reporter pincite could not be verified and is not used here. ### In re Kheir (Kheir v. Titan Team LLC), Adv. No. 25-3033 - Court: U.S. Bankruptcy Court for the Southern District of Texas - Jurisdiction: Federal (Bankr. S.D. Tex.) - Date: 2025-11-04 (precision: day) - Sanction type: Attorney ordered to reimburse the opposing party's reasonable attorney fees and costs (amount fixed by later fee application) - Amount: Opposing party's reasonable attorney fees and costs (amount set by fee application) - Rule basis: Rule 11; inherent authority - AI tool alleged: Generative-AI hallucinations — the court's admonition references ChatGPT ("No lawyer should be using ChatGPT or any other generative AI ...") but did not affirmatively find it as counsel's specific source - Verification status: verified-primary - Primary source: https://websitedc.s3.amazonaws.com/documents/Kheir_v._Titan_Team_The_Money_Source__Auction.com_USA_4_November_2025.pdf - Last verified: 2026-07-21 - Tracker id: in-re-kheir Chief Bankruptcy Judge Rodriguez ordered attorney Derrick D. King to reimburse the opposing party's fees and costs for a brief containing 32 fabricated or misrepresented AI-generated citations. Cited by docket because the reporter pincite could not be verified and is not used here. ### Johnson v. Dunn, No. 2:21-cv-1701-AMM - Court: U.S. District Court for the Northern District of Alabama - Jurisdiction: Federal (N.D. Ala.) - Date: 2025-07-23 (precision: day) - Sanction type: Public reprimand (with publication); disqualification from the case; referral to the Alabama State Bar and licensing authorities - Amount: None (non-monetary) - Rule basis: Inherent authority (the court held Rule 11 inapplicable to the discovery motions at issue) - AI tool alleged: Named — ChatGPT; three attorneys conceded the citations were ChatGPT hallucinations and the court so found - Verification status: verified-primary - Primary source: https://www.law.berkeley.edu/wp-content/uploads/archive/2025/12/Johnson-v-Dunn.pdf - Last verified: 2026-07-21 - Tracker id: johnson-v-dunn Reported at 792 F. Supp. 3d 1241. The court publicly reprimanded three Butler Snow attorneys, disqualified them from the case, and referred them to the Alabama State Bar after they filed ChatGPT-fabricated citations they conceded were hallucinations. The sanction was non-monetary and rested on the court's inherent authority. ### Kruse v. Karlen, No. ED111172 - Court: Missouri Court of Appeals, Eastern District - Jurisdiction: Missouri (state) - Date: 2024-02-13 (precision: day) - Sanction type: Damages for a frivolous appeal, toward respondent's appellate attorney fees; appeal dismissed - Amount: $10,000 (against self-represented appellant Jonathan Karlen) - Rule basis: Mo. Sup. Ct. R. 84.19 (also Rules 84.04, 55.03, 84.06(c)) - AI tool alleged: Unnamed generative AI — the court attributed 22 fictitious citations to a generative-AI tool; no specific tool named - Verification status: verified-primary - Primary source: https://caselaw.findlaw.com/court/mis-crt-app-eas-dis-div-two/115816278.html - Last verified: 2026-07-21 - Tracker id: kruse-v-karlen Reported at 692 S.W.3d 43. The Missouri Court of Appeals dismissed a self-represented appellant's appeal in which 22 of 24 case citations were fictitious and awarded $10,000 in frivolous-appeal damages, attributing the fabricated authorities to a generative-AI tool the appellant did not identify. ### Lnu v. Blanche, No. 24-4790 - Court: U.S. Court of Appeals for the Ninth Circuit - Jurisdiction: Federal (9th Cir.) - Date: 2026-06-03 (precision: day) - Sanction type: Monetary sanction; six-month suspension from practice before the Ninth Circuit; two-year AI-use certification condition on all filings; referral to the State Bar of California - Amount: $2,500 each (two attorneys) - Rule basis: FRAP 46(b); 9th Cir. R. 46-2(a) - AI tool alleged: None named in the order; the attorneys conceded it was "more likely than not" unauthorized generative-AI use by unlicensed brief writers - Verification status: verified-primary - Primary source: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/06/03/24-4790.pdf - Last verified: 2026-07-01 - Tracker id: lnu-v-blanche Published disciplinary order sanctioning Mike Singh Sethi and William Rounds for briefs filed "with multiple nonexistent cases, misattributed quotations, and gross misrepresentations of real cases," followed by repeated denials of AI use. Each attorney was fined $2,500 and suspended from practice before the Ninth Circuit for six months, with a two-year requirement that future filings disclose under penalty of perjury whether generative AI was used, name the tool, and certify personal review, and with the order referred to the State Bar of California. The court wrote that the rules "are not violated at the point of research and drafting, but at the point of signing and filing," and that the gravity of the discipline is owed to the repeated failure of candor. ### Mata v. Avianca, Inc., No. 22-cv-1461 (PKC) - Court: U.S. District Court for the Southern District of New York - Jurisdiction: Federal (S.D.N.Y.) - Date: 2023-06-22 (precision: day) - Sanction type: Monetary penalty payable to the Registry of the Court; mandatory notification letters to the client and to each judge falsely identified as the author of a fake opinion, with compliance filings - Amount: $5,000, jointly and severally (two attorneys and their law firm) - Rule basis: Fed. R. Civ. P. 11(b)(2), 11(c)(1), 11(c)(4), or alternatively the court's inherent power; a separate 28 U.S.C. § 1927 sanction was expressly declined - AI tool alleged: ChatGPT, expressly — the court found the fake opinions were "created by the artificial intelligence tool ChatGPT," and respondents acknowledged the six fabricated decisions were ChatGPT-generated - Verification status: verified-primary - Primary source: https://storage.courtlistener.com/recap/gov.uscourts.nysd.575368/gov.uscourts.nysd.575368.54.0.pdf - Last verified: 2026-07-19 - Tracker id: mata-v-avianca The foundational fabricated-citations sanctions decision (Castel, J.; reported at 678 F. Supp. 3d 443): Opinion and Order on Sanctions finding subjective bad faith by attorneys Peter LoDuca and Steven A. Schwartz — grounded in conscious avoidance and false and misleading statements to the court, not the ChatGPT use itself — and imposing a $5,000 penalty jointly and severally on both attorneys and Levidow, Levidow & Oberman P.C. The order dissects six fabricated decisions ("Varghese," "Shaboon," "Petersen," "Martinez," "Durden," "Miller"), including fake internal citations and a self-citing opinion, and requires respondents to notify their client and every judge whose name was falsely invoked. The court's much-quoted framing: "there is nothing inherently improper about using a reliable artificial intelligence tool for assistance," but existing rules "impose a gatekeeping role on attorneys to ensure the accuracy of their filings." ### Noland v. Land of the Free, L.P., No. B331918 - Court: California Court of Appeal, Second District, Division Three - Jurisdiction: California (state) - Date: 2025-09-12 (precision: day) - Sanction type: Monetary sanction payable to the clerk of the court; State Bar referral under Bus. & Prof. Code § 6086.7(a)(3); counsel ordered to serve the opinion on his client and certify service - Amount: $10,000 (against counsel only; the court found nothing indicating the client knew of the fabrications) - Rule basis: Code Civ. Proc. §§ 907, 128.7; Cal. Rules of Court, rule 8.276(a)(4); briefing violation of rule 8.204(a)(1)(B) - AI tool alleged: Found and conceded — the court found the fabricated authorities "were created by generative artificial intelligence (AI) tools"; counsel admitted drafting briefs, "enhancing" them with ChatGPT, running them through other AI platforms (his account names ChatGPT, Claude, Gemini, and Grok), and not reading the enhanced briefs before filing - Verification status: verified-primary - Primary source: https://www.law.berkeley.edu/wp-content/uploads/archive/2025/12/Noland-v-Land-of-the-Free-LP.pdf - Last verified: 2026-07-19 - Tracker id: noland-v-land-of-the-free Published opinion (114 Cal.App.5th 426, Edmon, P.J.) affirming summary judgment and sanctioning appellant's counsel Amir Mostafavi $10,000 payable to the clerk after finding 21 of the 23 case quotations in the opening brief were fabrications, with more in the reply brief and at least one cited case that does not exist. Published "as a warning," with the much-quoted holding that no filing should contain any citations — "whether provided by generative AI or any other source — that the attorney responsible for submitting the pleading has not personally read and verified." Both the Ninth Circuit's Lnu order and the Sixth Circuit's Whiting opinion quote this case; sanctions ran to the court's general fund rather than opposing counsel, who never flagged the fabrications. ### Powell v. Employment Department, No. A185894 - Court: Oregon Court of Appeals - Jurisdiction: Oregon (state) - Date: 2026-02-11 (precision: day) - Sanction type: Monetary sanction against a self-represented petitioner, payable to the OJD Appellate Court Services Division - Amount: $500 (against self-represented petitioner Keith Powell) - Rule basis: ORCP 17 C(1) and D(1), via ORAP 1.40(4) - AI tool alleged: Conceded (unnamed) — the petitioner attributed the fabricated authority to "online search engines and AI-assisted legal research sites" - Verification status: verified-primary - Primary source: https://law.justia.com/cases/oregon/court-of-appeals/2026/a185894.html - Last verified: 2026-07-21 - Tracker id: powell-v-employment-dept Reported at 347 Or App 55. The Oregon Court of Appeals fined a self-represented petitioner $500 for citing fabricated cases he conceded came from online search engines and AI research sites — one of the few sanctions in this dataset against a pro se party rather than an attorney. ### Prososki v. Regan, No. S-25-295 - Court: Nebraska Supreme Court - Jurisdiction: Nebraska (state) - Date: 2026-03-20 (precision: day) - Sanction type: Appellant's brief stricken; appeal dismissed; counsel referred to the Counsel for Discipline of the Nebraska Supreme Court - Amount: None (non-monetary; the court noted its ruling does not preclude the appellee from seeking attorney fees) - Rule basis: Inherent authority; Neb. Ct. R. App. P. § 2-109(D)(1)(e) briefing mandate; referral for investigation of potential violations of Neb. Ct. R. of Prof. Cond. §§ 3-503.3(a)(1) (candor), 3-501.1 (competence), 3-501.3 (diligence), 3-503.1 (meritorious claims), and 3-508.4(c) (misconduct) - AI tool alleged: None found — the appellee asserted the fabrications were the product of generative AI; counsel denied inventing cases or relying on AI; the court expressly declined to resolve the question, holding that "[r]egardless of whether AI was used" the analysis is the same - Verification status: verified-primary - Primary source: https://www.nebraska.gov/apps-courts-epub/public/viewOpinion?docId=N00013081PUB - Last verified: 2026-07-19 - Tracker id: prososki-v-regan Per curiam opinion (321 Neb. 38) striking an appellate brief that contained "numerous citations to fake cases, real cases with fake quotations, real cases with mischaracterized holdings, and Nebraska statutes and court rules with fake quotations," dismissing the appeal, and referring counsel to the Counsel for Discipline. The opinion prints a chart of roughly twenty problematic citations, including a fictitious "Kennedy v. Kennedy" cited and quoted five times, and holds that submitting fictitious authority — "whether through generative AI or not" — is resolved by existing candor, competence, and frivolous-claim rules. The court reviewed the record for plain error despite striking the brief, found none, and affirmed on the cross-appeal. ### Ringo v. Colquhoun Design Studio, LLC, No. A186670 - Court: Oregon Court of Appeals - Jurisdiction: Oregon (state) - Date: 2025-12-03 (precision: day) - Sanction type: Monetary sanction against appellee's counsel, payable to the OJD Appellate Court Services Division - Amount: $2,000 ($500 per fabricated citation x 2, plus $1,000 per false quotation x 1), against attorney Gabriel A. Watson - Rule basis: ORCP 17 C(3), via ORAP 1.40(4) - AI tool alleged: Unnamed generative AI — court-inferred; the court "recognize[d] ... the fabricated law in respondents' brief likely resulted from the use of artificial intelligence," though counsel did not directly admit it - Verification status: verified-primary - Primary source: https://law.justia.com/cases/oregon/court-of-appeals/2025/a186670.html - Last verified: 2026-07-21 - Tracker id: ringo-v-colquhoun Reported at 345 Or App 301. This decision originates Oregon's per-infraction fee schedule for AI-fabricated authority ($500 per fabricated citation, $1,000 per false quotation), sanctioning appellee's counsel Gabriel A. Watson $2,000. Some secondary trackers caption this matter by the attorney's name, Watson; it is a single case, not two. ### United States v. Farris, No. 25-5623 - Court: U.S. Court of Appeals for the Sixth Circuit - Jurisdiction: Federal (6th Cir.) - Date: 2026-04-03 (precision: day) - Sanction type: Forfeiture of Criminal Justice Act compensation for the appeal; removal from the representation; disciplinary referrals (Sixth Circuit and E.D. Ky. Chief Judges; Kentucky Bar) - Amount: None fixed (CJA fee forfeiture plus referrals) - Rule basis: 18 U.S.C. § 3006A; 6th Cir. Local Rule 46; CJA Plan; inherent authority - AI tool alleged: Named — Westlaw's CoCounsel ("Westlaw's internal artificial-intelligence platform"); the cited cases were real but their quotations were fabricated or misstated - Verification status: verified-primary - Primary source: https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0105p-06.pdf - Last verified: 2026-07-21 - Tracker id: us-v-farris The Sixth Circuit stripped attorney Steven N. Howe of his CJA compensation, removed him from the representation, and made three disciplinary referrals for a brief whose quotations were fabricated by Westlaw's CoCounsel AI. Cited by docket: secondary sources circulate an incorrect Westlaw citation; the correct cite is 2026 WL 710568. ### United States v. Hayes, No. 2:24-cr-0280-DJC - Court: U.S. District Court for the Eastern District of California - Jurisdiction: Federal (E.D. Cal.) - Date: 2025-01-17 (precision: day) - Sanction type: Monetary sanction against counsel personally; the order served on the D.C. Bar and the State Bar of California and circulated to the court's judges - Amount: $1,500 (against Assistant Federal Public Defender Andrew Francisco) - Rule basis: E.D. Cal. Local Rule 180(e); inherent authority - AI tool alleged: No express AI finding — the court said the fabricated citation "has all the markings of a hallucinated case created by generative artificial intelligence (AI) tools such as ChatGPT and Google Bard" but "need not make any finding" on actual AI use - Verification status: verified-primary - Primary source: https://www.damiencharlotin.com/documents/234/USA_v._Hayes_US_DC_Eastern_California_January_17_2025.pdf - Last verified: 2026-07-21 - Tracker id: us-v-hayes The court sanctioned an Assistant Federal Public Defender $1,500 for a fabricated case citation bearing the hallmarks of AI, expressly declining to find that AI was in fact used. Cited by docket; the "763 F. Supp. 3d 1054" reporter pincite was not independently confirmed. This corrects a roster note that had flagged Hayes as authority-only: it imposed its own sanction. ### Wadsworth v. Walmart, Inc., No. 2:23-cv-118-KHR - Court: U.S. District Court for the District of Wyoming - Jurisdiction: Federal (D. Wyo.) - Date: 2025-02-24 (precision: day) - Sanction type: Monetary sanctions payable to the court registry; one attorney's pro hac vice admission revoked - Amount: $5,000 total — $3,000 (Ayala), $1,000 (T. Morgan), $1,000 (Goody) - Rule basis: Fed. R. Civ. P. 11(b)(2); inherent authority - AI tool alleged: Conceded generative AI — an internal Morgan & Morgan AI platform; the court expressly noted it "appears Plaintiffs' attorneys did not use ChatGPT." Not a ChatGPT case. - Verification status: verified-primary - Primary source: https://caselaw.findlaw.com/court/us-dis-crt-d-wyo/117003959.html - Last verified: 2026-07-21 - Tracker id: wadsworth-v-walmart Reported at 348 F.R.D. 489. The court sanctioned three Morgan & Morgan attorneys a total of $5,000 (and revoked one pro hac vice admission) after eight of nine cited cases proved nonexistent, generated by the firm's internal AI platform. The court specifically found the fabrications did not come from ChatGPT, and the dataset preserves that distinction. ### Whiting v. City of Athens, Tenn., Nos. 24-5918/5919, 25-5424 - Court: U.S. Court of Appeals for the Sixth Circuit - Jurisdiction: Federal (6th Cir.; appeals from E.D. Tenn.) - Date: 2026-03-13 (precision: day) - Sanction type: Punitive monetary sanction payable to the court registry; joint and several liability for appellees' full reasonable attorneys' fees on appeal; double costs under 28 U.S.C. § 1920; referral to the chief judge to consider disciplinary proceedings under 6th Cir. Local Rule 46 - Amount: $15,000 each (two attorneys), plus fees and double costs - Rule basis: FRAP 38 (appeal frivolous as argued); inherent authority (bad faith) - AI tool alleged: None — the court made no express finding that generative AI produced the fabrications; the attorneys never answered the show-cause order's question whether they used AI - Verification status: verified-primary - Primary source: https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0080p-06.pdf - Last verified: 2026-07-01 - Tracker id: whiting-v-city-of-athens Published opinion sanctioning Van R. Irion and Russ Egli for briefs containing "over two dozen fake citations and misrepresentations of fact" — the court's conservative estimate, itemized in an appendix — across three consolidated appeals. This is a fabricated-citations case, not a confirmed AI case: the court made no express AI finding because the attorneys did not respond to the show-cause directive asking whether AI was used. ### Williams v. Honl, No. A186656 - Court: Oregon Court of Appeals - Jurisdiction: Oregon (state) - Date: 2026-04-22 (precision: day) - Sanction type: Award of respondent's attorney fees against appellant's attorneys - Amount: $8,044.25 (against appellant's attorneys) - Rule basis: ORAP 1.40 and ORCP 17 (fees via ORCP 17 D(4)); RPC 3.3 (candor) - AI tool alleged: Unnamed generative AI — "Appellant's attorney did not identify what generative artificial intelligence product she used"; six of nine cited cases were fabricated or misused - Verification status: verified-primary - Primary source: https://storage.courtlistener.com/pdf/2026/04/22/williams_v._honl.pdf - Last verified: 2026-07-21 - Tracker id: williams-v-honl Reported at 348 Or App 505. The court ordered appellant's attorneys to pay $8,044.25 in respondent's attorney fees for a brief in which six of nine cited cases were fabricated or misused by an unidentified generative-AI tool, treating the uncorrected record as a candor violation.