As artificial intelligence becomes more integrated into legal practice, courts are increasingly issuing strong sanctions against attorneys who misuse AI tools — particularly when it leads to fabricated legal citations.

BatesCarey’s Ommid Farashahi and Melissa Gandhi examine a recent ruling in Frankie Johnson v. Jefferson S. Dunn, et al., in which attorneys faced substantial sanctions, including fines, public reprimands, and disqualification for submitting fictitious legal authorities generated by artificial intelligence.

Judge Anna Manasco’s July 2025 sanctions order underscores the judiciary’s growing intolerance for AI misuse, emphasizing the need for deterrence and professional accountability. Importantly, law firms with proactive AI governance — such as internal committees and verification protocols — may avoid institutional penalties even when individual attorneys are sanctioned.

Ommid and Melissa stress that while AI may transform legal workflows, it does not absolve lawyers of their ethical duties. Courts are drawing a clear line: AI tools must be used responsibly.

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Ommid Farashahi is a member of the Firm's Management Committee and the Chair of the Firm's Professional Liability Coverage Group. He serves as coverage and litigation counsel to domestic and international insurers in various professional liability coverage matters, including Cyber exposures arising from healthcare providers and facilities.

Melissa Gandhi is a Special Counsel focusing her practice in several insurance product lines, including D&O, EPL and LPL claims.