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SanctionsUS · FederalMarch 13, 2026

Sixth Circuit orders $15,000 per attorney, full appellate fees and double costs over fabricated citations

In brief

In Whiting v. City of Athens, a Sixth Circuit panel sanctioned two attorneys whose briefs contained more than two dozen fabricated citations and misrepresentations, ordering each to pay $15,000, reimburse the opposing party’s appellate fees, pay double costs, and referring them for discipline.

Why it matters: The panel stated that no filing should contain citations, from AI or any other source, that the lawyer has not personally read and verified. That is now the federal appellate baseline.

The sanctions covered three consolidated appeals. Beyond the monetary penalties, the court referred both attorneys for disciplinary review.

Use this: run every draft through our free AI Citation Checker to build a verification list, then open each authority yourself.

General information, not legal advice. Check the primary source and any later developments before relying on this summary.

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