Incident 1447: Sixth Circuit Sanctioned Lawyers in Whiting v. City of Athens over Alleged Fake Appellate Citations in Briefs Reportedly Bearing Hallmarks of Hallucinations

Description: The U.S. Court of Appeals for the Sixth Circuit sanctioned attorneys Van Irion and Russ Egli after reportedly finding more than two dozen fake citations and alleged factual misrepresentations in appellate briefs in Whiting v. City of Athens. The court asked whether generative AI had been used, but the attorneys reportedly did not answer that question. Public reporting described the filings as bearing hallmarks of AI hallucinations.

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Incident Stats

Incident ID
1447
Report Count
4
Incident Date
2026-03-13
Editors
Daniel Atherton
Applied Taxonomies
MIT

MIT Taxonomy Classifications

Machine-Classified
Taxonomy Details

Risk Subdomain

3.1. False or misleading information

Risk Domain

  1. Misinformation

Entity

AI

Timing

Post-deployment

Intent

Unintentional

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US appeals court fines lawyers $30,000 in latest AI-related sanction
reuters.com · 2026

March 16 (Reuters) - An appeal containing fake case citations that misrepresent the law can be dismissed as frivolous, a U.S. federal appeals court panel said in a decision sanctioning ​two attorneys who submitted filings that bore hallmark…

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Sixth Circuit Sanctions Attorneys for Fake Citations – What Does This Mean for Use of AI?
sixthcircuitappellateblog.com · 2026

The Sixth Circuit finally weighed in on the use of fake cases hallucinated by artificial intelligence. A panel recently sanctioned two Tennessee attorneys for a smorgasbord of misconduct during merits briefing, including citing fake cases. …

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Sixth Circuit Sanctions Attorneys for Fake Citations – What Does This Mean for Use of AI?
natlawreview.com · 2026

The Sixth Circuit finally weighed in on the use of fake cases hallucinated by artificial intelligence. A panel recently sanctioned two Tennessee attorneys for a smorgasbord of misconduct during merits briefing, including citing fake cases. …

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Fabricated Citations, Real Consequences: The Sixth Circuit’s Multi-Pronged Response to Attorney Misconduct
reminger.com · 2026

The Sixth Circuit's recent decision in Whiting v. City of Athens, 2026 U.S. App. LEXIS 7479, is a significant ruling addressing attorney misconduct, particularly the submission of fabricated legal citations and misrepresentations in appella…

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