The largest sanction I have seen to date for filing hallucinated AI citations now stands at $85,567.75
The case is Byoplanet International, LLC v. Johansson and Gilstrap, No. 24-cv-60630, 2025 WL 3091094 (S.D. Fla. Aug. 1, 2025)
On August 1, 2025, Judge Leibowitz of the Southern District of Florida ordered this sanction against plaintiffs’ counsel following extensive misuse of generative AI. The original sanctions were imposed on July 15, 2025, across four consolidated cases. The court ordered counsel to compensate defendants’ attorneys “for all time spent responding to any filing in which generative AI was used to develop hallucinated cases and fabricated quotations.”
A fee dispute followed. The parties were directed to confer and reach an agreeable amount. Defendants’ counsel ultimately proposed $85,567.75. Plaintiffs’ counsel countered with $46,731.
In a subsequent order, the court remarked that it was “shocked, shocked to find that no agreement has been reached.” The court found that “Defendants’ discounted fees and costs are reasonable based on prevailing market rates and that Defendants’ concessions are sufficient.”
The court then ordered plaintiffs’ counsel to pay the full $85,567.75
This is now a leading cautionary example of the financial consequences of improper reliance on generative AI in litigation.
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