Connecticut Court Sanctions Lawyer Over ChatGPT-Altered Citations
The Connecticut Supreme Court on July 31 sanctioned attorney Ian G. Gottlieb and GLG Law after ChatGPT added or altered about seven citations in filings for two cases, even though the underlying legal research had been checked before the AI editing pass. The court required additional education, separate $1,000 donations from the lawyer and firm, and a compliance report within six months.
The Connecticut Supreme Court issued a July 31 sanctions order after attorney Ian G. Gottlieb submitted filings in two cases with about seven erroneous and unverified citations produced during a ChatGPT editing pass. The order covers TOV Realty, LLC v. Suarez and Kosel Equity, LLC v. MacGregor.
Verified research changed during editing
According to the court, Gottlieb initially researched the filings with LexisNexis and verified quotations and citations in rough drafts through Shepard's Citations Service. He then pasted the drafts into ChatGPT to improve their organization and writing. The resulting drafts added new citations or altered existing ones, but the filings were not cite-checked again because the underlying legal propositions remained accurate.
Amici represented by the Jerome N. Frank Legal Services Organization alerted the court and counsel to the apparent hallucinations. Gottlieb later filed errata and corrected the briefs. At a July 7 show-cause hearing, he accepted responsibility and admitted that the approximately seven erroneous citations violated the professional duty of competence. The court found no intent to deceive and cited his cooperation, contrition, and lack of disciplinary history as mitigating factors.
The sanctions and the control lesson
The court ordered Gottlieb to complete six additional hours of continuing legal education in ethics and law-office management, including three hours on generative AI. It also ordered Gottlieb and GLG Law to each donate $1,000 to the CT Bar Institute and required them to report compliance within six months. Gottlieb must also comply with reciprocal-discipline obligations in any other jurisdiction where he is admitted.
The order pointed to new Connecticut practice rules requiring anyone who uses generative AI to create or edit a court filing to independently verify citations, legal authorities, and evidence. Those rules took effect in June and July 2026.
The operational lesson is narrower than a ban on AI-assisted editing: validation must occur after the final transformation. A citation check performed before an AI rewrite does not cover citations the model later changes or inserts. Legal, research, and compliance teams using generative AI should therefore treat the final generated draft as unverified until every authority and factual claim has been checked against the underlying source.
Key Points
- 1The court said ChatGPT added or altered about seven citations after the lawyer had already verified the research in the original rough drafts.
- 2Sanctions included six additional education hours, separate $1,000 donations from the lawyer and firm, and a compliance report within six months.
- 3The order reinforces a post-edit verification rule: checking citations before an AI transformation does not validate the final filing.
Scoring Rationale
A state supreme court imposed concrete sanctions and connected the misconduct to new verification rules for AI-assisted filings. The decision offers a clear control lesson for professional workflows, though its direct legal scope is limited to the lawyers and matters before the court.
Sources
Primary source and supporting public references used for this report.
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