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Incident 1577: Lawyer in Amarsingh v. Frontier Airlines Sanctioned Over Court-Identified ChatGPT Citation Errors

Description: In Amarsingh v. Frontier Airlines, the Tenth Circuit sanctioned attorney Kusmin L. Amarsingh after finding that her appellate brief included fabricated case citations and misattributed legal authority generated by ChatGPT and not verified before filing. The court ordered a $1,000 payment to Frontier and referred the matter to Maryland disciplinary authorities.
Editor Notes: Timeline notes: The incident ID date is 01/24/2025, based on the Tenth Circuit's identification of that date as the time of the infraction involving AI-generated citations in Kusmin L. Amarsingh's appellate brief. The court issued a show-cause order on 09/05/2025 and, on 02/09/2026, affirmed the district court's judgment while imposing sanctions and directing referral to the Maryland disciplinary authority. The incident ID was created on 07/08/2026. See also: https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111382504.pdf.

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Alleged: OpenAI , Large language model developers , Chatbot developers and AI research tool developers developed an AI system deployed by Pro se litigants , Lawyers and Kusmin L. Amarsingh, which harmed United States Court of Appeals for the Tenth Circuit , Judicial integrity , Frontier Airlines and Epistemic integrity.
Alleged implicated AI systems: Large language models , ChatGPT , Chatbots and AI research tools

Incident Stats

Incident ID
1577
Report Count
2
Incident Date
2025-01-24
Editors
Daniel Atherton

Incident Reports

Reports Timeline

Incident Occurrence+1
10th Circuit orders lawyer to pay $1,000 for faulty AI citations
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10th Circuit orders lawyer to pay $1,000 for faulty AI citations

10th Circuit orders lawyer to pay $1,000 for faulty AI citations

coloradopolitics.com

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Appeals Court Sanctions Lawyer Over AI-Hallucinated Errors

Appeals Court Sanctions Lawyer Over AI-Hallucinated Errors

news.bloomberglaw.com

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10th Circuit orders lawyer to pay $1,000 for faulty AI citations
coloradopolitics.com · 2026

The Denver-based federal appeals court ordered a lawyer on Monday to pay $1,000 to the opposing side for submitting a legal filing with fake case citations generated by artificial intelligence.

A three-judge panel of the U.S. Court of Appea…

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Appeals Court Sanctions Lawyer Over AI-Hallucinated Errors
news.bloomberglaw.com · 2026

A Maryland lawyer has been sanctioned by a federal appeals court after admitting to using a generative AI tool to draft a brief that cited multiple nonexistent cases.

Kusmin L. Amarsingh on Monday was sanctioned $1,000 by the US Court of Ap…

Variants

A "variant" is an AI incident similar to a known case—it has the same causes, harms, and AI system. Instead of listing it separately, we group it under the first reported incident. Unlike other incidents, variants do not need to have been reported outside the AIID. Learn more from the research paper.
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