# What Determines an AI Sanction: Six 2026 Decisions

> Six courts, three months, and outcomes from $15,000 each down to nothing at all. What separated them was not the fabrication. It was what the lawyer did next.

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# Six AI Sanctions Decisions, One Discharge: What Actually Determines the Outcome
Between February and April 2026, six federal courts addressed lawyers who filed AI-fabricated material. The outcomes ranged from $15,000 per attorney plus fees, double costs and a disciplinary referral, down to a show-cause order discharged with no sanction at all. The conduct that triggered them was broadly the same. What separated them was almost entirely what the lawyer did after being caught.

By [Jamie Kloncz](https://rankshieldlegal.com/about/), Founder, RankShield ** 20 min read ** Published September 9, 2026

This site has covered what gets a lawyer sanctioned for AI-fabricated citations from several directions: the point of signing, the gap where Rule 11 does not reach, the adversary's motion, and the disciplinary proceeding that follows. All of those are about the offense. None answers the question a lawyer actually asks once it has happened to them, which is what determines how badly this goes.
Norton Rose Fulbright's survey of 2026 Gen AI sanctions decisions supplies an unusually clean dataset for that question: six decisions in roughly three months, across four federal circuits and two district courts [[1]](#ref-1). Two of them are independently verifiable in the public record. Glenn Whiting v. City of Athens, Tenn. was decided by the Sixth Circuit on March 13, 2026 under docket numbers 25-5424 and 25-5425 [[2]](#ref-2). Fletcher v. Experian Information Solutions was decided by the Fifth Circuit on February 18, 2026 [[3]](#ref-3).
The spread is the striking part. In Whiting, the court imposed attorneys' fees, double costs, $15,000 in punitive sanctions against each attorney, and a disciplinary referral. In Gamez v. County of Fresno, the Eastern District of California discharged its show-cause order and imposed nothing [[1]](#ref-1).
The survey identifies the variable, and it is not the number of fabricated citations. Candor when confronted operates as a mitigating factor, candor alone does not prevent sanctions, and evasiveness significantly aggravates them. The survey also concludes that existing rules are sufficient to address the misconduct, and that courts are signaling that lighter sanctions may be drawing to a close [[1]](#ref-1).
This article is written from the perspective of a verification vendor, not a law firm, and it is informational rather than legal advice. The characterizations of these decisions are drawn from the survey rather than from the orders themselves, and are attributed accordingly. Read the orders before relying on any account of them, including this one.

## The six decisions, and the distance between them
Four circuit decisions and two district decisions between February and April 2026. Sanctions ranged from $15,000 per attorney with fees, double costs and a referral, through public reprimand and admonishment, to a $2,500 penalty, to case removal with denial of compensation, to nothing at all [[1]](#ref-1).
Laid side by side, the range is wider than most firms assume. These are not distinguishable by jurisdiction or by era; they are contemporaneous decisions from courts applying the same body of authority to the same category of conduct.
The heaviest is Whiting, where the Sixth Circuit imposed attorneys' fees, double costs, $15,000 in punitive sanctions on each attorney, and a disciplinary referral [[1]](#ref-1). Multiple consequence classes in one order, which is the pattern our analysis of [Johnson v. Dunn](https://rankshieldlegal.com/blog/johnson-v-dunn-rule-11-gap-ai-sanctions) identified as the direction of travel.
United States v. Farris, also from the Sixth Circuit, is the one that introduces a consequence firms rarely model: alongside removal from the case and disciplinary referrals, the court denied Criminal Justice Act compensation [[1]](#ref-1). Under the CJA, appointed counsel in federal criminal matters are compensated from public funds [[4]](#ref-4). Denial means the lawyer did the work and was not paid for it, which is a sanction that never appears in a fine schedule.
At the other end, Gamez v. County of Fresno produced no sanction. The Eastern District of California discharged its order to show cause in April 2026 [[1]](#ref-1). Same category of conduct, no penalty.
Fletcher v. Experian sits low on the monetary scale at $2,500 under Federal Rule of Appellate Procedure 46(c), which authorizes a court of appeals to discipline an attorney for conduct unbecoming the court or for failure to comply with applicable rules [[3]](#ref-3) [[5]](#ref-5). In re Nwaubani drew a public admonishment for conduct the court described as seriously interfering with the administration of justice, and Fivehouse v. U.S. Department of Defense drew a public reprimand [[1]](#ref-1).
Decision Court and date Outcome [1]
Whiting v. City of Athens, Tenn. 6th Cir., March 13 2026 [2] Fees, double costs, $15,000 each, disciplinary referral
United States v. Farris 6th Cir., 2026 Removal from the case, denial of CJA compensation, referrals
In re Eric Chibueze Nwaubani 4th Cir., March 2026 Public admonishment
Fivehouse v. U.S. Dep't of Defense E.D.N.C., April 2026 Public reprimand
Fletcher v. Experian Info. Solutions 5th Cir., Feb 18 2026 [3] $2,500 under FRAP 46(c)
Gamez v. County of Fresno E.D. Cal., April 2026 None; show-cause order discharged

## Candor mitigates, and it is not enough on its own
The survey's central finding is a pair, and firms tend to hear only half of it. Attorney candor when confronted with errors operates as a mitigating factor. Candor alone does not prevent sanctions. Both halves matter, because a lawyer who expects an admission to end the matter has misread what the mitigation actually buys [[1]](#ref-1).
The first half is the part worth acting on immediately. Whatever else is true on the day a court asks about a citation, candor improves the position. It is the single variable most within the lawyer's control at that point, and it is free.
The second half is the corrective. Admitting the error does not make the sanction go away; it changes where in the range the outcome lands. A lawyer who is fully candid may still be reprimanded, still be referred, still pay. What candor appears to affect is severity, not existence.
That distinction matters for how a firm counsels a lawyer in the first hour. Advice framed as "tell the court and this will be fine" sets an expectation the record does not support, and a lawyer who is surprised by a sanction after being honest is a lawyer who was badly advised. The accurate framing is that candor is the cheapest available mitigation and it is not a defense.
It also aligns with what the disciplinary track rewards. Our analysis of [the second proceeding at the state bar](https://rankshieldlegal.com/blog/state-bar-discipline-after-ai-citation-sanctions) found the same pattern: the response after discovery carried more weight than the governance before it. Two different forums, applying different standards, converging on the same variable.

Source: Norton Rose Fulbright survey of 2026 Gen AI sanctions decisions Download SVG

## Evasiveness is the aggravator that costs the most
The survey is explicit that evasiveness significantly aggravates penalties [[1]](#ref-1). That is the mirror of the candor finding and the more consequential half, because evasiveness is a choice made under pressure, usually by someone who has not decided in advance how they will respond.
The pattern recurs across the reported AI-sanctions cases well beyond this survey. The Ninth Circuit's decision in LNU v. Blanche turned substantially on the combination of fabricated authority and a lack of candor about its source. Del Biaggio v. Bansen sanctioned counsel for the misstatements and for a correction that arrived more than three months after notice.
The reason evasiveness is so expensive is that it converts one problem into two, and the second is worse. A fabricated citation is a competence and verification failure. Concealing or minimizing it once asked is a candor problem, and candor problems go to fitness rather than carefulness.
It is worth being precise about what counts as evasive, because most of it is not deliberate deception. Answering a narrower question than the one asked, describing the error without describing how it happened, attributing it to a process rather than a person, and delaying a correction while the firm decides on a position all read as evasive from the bench even when nobody intended to mislead.
There is a structural reason lawyers slide into it. The instinct that serves you well in litigation, which is to concede no more than the question strictly requires, is precisely wrong here. A show-cause order is not a discovery request from an adversary; it is the court asking a question about your conduct, and answering it narrowly reads as management rather than candor.
The practical implication is that the response should be decided before it is needed. A lawyer improvising under a show-cause order at 6pm is the person most likely to shade an answer, and the shading is what the court will weigh.

## The discharge: what a court does when it imposes nothing
Gamez v. County of Fresno is the most useful decision in the set precisely because nothing happened. The Eastern District of California issued an order to show cause and then discharged it in April 2026 without imposing a sanction [[1]](#ref-1). A discharge is not an acquittal, and it is not luck.
Courts issue show-cause orders to require an explanation, not to announce a penalty. The order is a question. A discharge means the answer was sufficient.
That reframes what the response is for. A lawyer receiving a show-cause order is not primarily defending against a sanction; they are answering a question about how this happened and what has been done about it. Those are answerable in a way that "please do not sanction me" is not.
What the survey's broader findings suggest a sufficient answer contains is consistent across the set: candor about what occurred, an account of the cause rather than a description of the symptom, and evidence of remediation. Johnson v. Dunn made the same point from the opposite direction, treating an internal review and an independent outside investigation as reassuring enough that suspension was unnecessary.
The caution is that a discharge in one case tells you nothing reliable about another. Facts differ, judges differ, and the survey itself notes that courts are signaling that lighter sanctions may be drawing to a close [[1]](#ref-1). A lawyer planning on a discharge is planning on the least predictable outcome in the set.
The useful takeaway is narrower and more durable: the range genuinely includes zero, and where a case lands within it is substantially determined after the filing rather than by it.
$0 to $15k the spread across six decisions in roughly three months, on broadly the same category of conduct [1]

## No new rule is coming, and that is the finding
The survey concludes that existing rules sufficiently address Gen AI misconduct [[1]](#ref-1). Courts are not waiting for an AI-specific sanctions rule, and firms should stop treating the absence of one as a gap. The authority already exists and is being used.
A recurring hope in firm discussions is that the profession is in an interim period before proper rules arrive, and that current enforcement is therefore improvised. The pattern across these decisions says otherwise.
Each of the six rests on ordinary authority. Fletcher applied Federal Rule of Appellate Procedure 46(c), which lets a court of appeals discipline an attorney for conduct unbecoming the court or failure to comply with the rules, and which long predates generative AI [[5]](#ref-5). Farris used case removal and denial of compensation, both ordinary case-management powers. Public reprimand and admonishment are conventional appellate tools.
That matches what courts have said explicitly elsewhere. The Ninth Circuit reached its conclusion through Rule 11 and inherent authority, and the Johnson v. Dunn court proceeded under inherent authority precisely because it found Rule 11 inapplicable, without suggesting anything was missing from the rulebook.
The consequence for planning is that there is no rule change to wait for and no grace period to rely on. A firm's exposure is governed by rules that already existed, applied by courts that have now had two years of practice applying them.
The survey's other signal points the same way: courts are indicating that lighter sanctions may be drawing to a close [[1]](#ref-1). Whatever leniency attached to novelty is being withdrawn as the conduct stops being novel.

## Consequences that never appear in a fine schedule
Across these six, the monetary figure is frequently the smallest part. Denial of Criminal Justice Act compensation, removal from a case, public reprimand, admonishment, double costs, opposing party's fees, and disciplinary referral all appear, and most of them have no fixed number attached [[1]](#ref-1) [[4]](#ref-4).
Firms that model AI-citation risk as a fine are modeling the least significant variable, which is a point this site has now made from three separate directions.
Farris is the clearest illustration. Denial of CJA compensation means appointed counsel performed the work and was not paid from the fund that exists to pay it [[1]](#ref-1) [[4]](#ref-4). That is not a penalty in the ordinary sense; it is the withdrawal of a payment, and it does not appear in any tally of AI sanctions organized by dollar amount.
Removal from a case carries a client consequence as well as a professional one, and the client did nothing wrong. Double costs and the opposing party's fees scale with how far the litigation ran rather than with the severity of the fabrication. A disciplinary referral, as our [analysis of the disciplinary track](https://rankshieldlegal.com/blog/state-bar-discipline-after-ai-citation-sanctions) sets out, starts a second proceeding with its own timeline and its own remedies against the license.
Public reprimand and admonishment are the ones most often dismissed as symbolic, and they are the most durable. A reprimand in a published decision is retrievable by name indefinitely, which makes it the consequence most likely to be found by a prospective client or a hiring committee years later.
Set against that, the monetary components are the ones a firm can absorb and forget. A $2,500 penalty under FRAP 46(c) is a line item; a public admonishment for conduct seriously interfering with the administration of justice is a description of the lawyer that stays attached to their name [[1]](#ref-1) [[5]](#ref-5).
The asymmetry is worth stating plainly to anyone modelling this risk. The costs that can be quantified are the ones that end, and the costs that cannot be quantified are the ones that persist. A risk register that captures only the first has inverted the actual exposure.

## Two years in, the leniency is being withdrawn
The survey's closing signal is that courts are indicating lighter sanctions may be drawing to a close [[1]](#ref-1). That is a statement about time rather than about conduct. Whatever allowance attached to generative AI being new is being withdrawn now that it is not.
Early AI-citation cases carried an implicit discount. The technology was unfamiliar, the failure mode was not widely understood, and courts imposing modest fines were addressing something the profession had not yet absorbed.
That reasoning has an expiry date built into it, and these six decisions sit past it. By early 2026 the risk had been the subject of published appellate opinions, state bar guidance, court standing orders, and a great deal of professional commentary. A lawyer filing unverified authority in 2026 is not doing something the profession failed to warn them about.
The Johnson v. Dunn court made the same move in aggravation, noting that the attorneys had benefitted from repeated warnings, internal controls, and firm policies before the failure happened anyway. Knowledge of the risk is now assumed, and an argument that leans on novelty is arguing against a premise no court still accepts.
The practical consequence is that older sanctions figures are a poor guide to current exposure. A firm calibrating its risk on the modest fines reported in the first wave is using a baseline the courts have signaled they are moving away from, and the six decisions here already show the spread widening at the top.
It also means the mitigation available has narrowed to conduct. Novelty is no longer a mitigating fact, unfamiliarity is not a defense, and what remains within the lawyer's control is the response, which is where this survey locates the difference between outcomes in any event [[1]](#ref-1).

## Decide the response before you need it
Every variable the survey identifies as decisive operates after the filing: candor, promptness, the quality of the explanation, and evidence of remediation [[1]](#ref-1). All of them are degraded by improvisation, and all of them can be decided in advance.
The uncomfortable implication of a dataset like this is that the most consequential decisions are made by a lawyer under pressure who has never thought about the question before.
A firm that has decided in advance who is told, who investigates, who speaks to the court, and what the standing instruction is about candor has removed the improvisation that produces evasive answers. Our guide to [the AI incident response plan](https://rankshieldlegal.com/blog/law-firm-ai-incident-response-plan) covers the mechanics; this dataset is the argument for why the plan changes outcomes rather than merely documenting them.
The standing instruction is the part worth writing down explicitly, because it is counterintuitive under pressure. Full candor, immediately, including about cause, is the position that mitigates, and partial candor that answers a narrower question than the one asked is the position that aggravates.

- **Treat a show-cause order as a question, not an accusation** Gamez was discharged. Courts issue these to require an explanation; a sufficient answer ends the matter. Answering the question asked is a different exercise from arguing against a penalty [[1]](#ref-1).
- **Be candid immediately, and about the cause** Candor is a mitigating factor and it is the cheapest one available. Describe how it happened, not only what happened; an account that omits the mechanism reads as evasive even when nothing is hidden [[1]](#ref-1).
- **Do not expect candor alone to prevent a sanction** The survey is explicit that it does not. Advising a lawyer that honesty will resolve it sets an expectation the record does not support, and it affects severity rather than existence [[1]](#ref-1).
- **Correct on the day you know** Delay while the firm settles on a position is read as evasiveness. Del Biaggio weighed a correction that arrived three months after notice, and that timing was part of the sanction.
- **Bring remediation with you, ideally independent** Evidence that the cause has been addressed is what converts an explanation into a sufficient answer. An outside review carries weight an internal one does not.
- **Assume no rule change is coming** The authority already exists and courts are signaling that lighter sanctions are ending. There is no interim period to wait out [[1]](#ref-1).

Test yourself
## Test yourself on what drives the outcome
Five questions on the variable that decides where in the range a case lands.

- 1 Across the six 2026 decisions, what most separated the outcomes? The number of fabricated citations What the lawyer did after being confronted Which circuit heard it **Answer:** What the lawyer did after being confronted The conduct was broadly the same category across all six, yet outcomes ranged from $15,000 each with fees and a referral down to a discharged show-cause order. The survey identifies candor as mitigating and evasiveness as significantly aggravating.
- 2 Does immediate candor prevent a sanction? Yes, courts credit honesty No, it affects severity rather than existence Only in district courts **Answer:** No, it affects severity rather than existence The survey is explicit on both halves: candor when confronted is a mitigating factor, and candor alone does not prevent sanctions. Advising otherwise sets an expectation the reported decisions do not support.
- 3 What did the Sixth Circuit's Farris response include that rarely appears in sanctions tallies? A suspension from practice Denial of Criminal Justice Act compensation A referral to the Department of Justice **Answer:** Denial of Criminal Justice Act compensation Alongside removal from the case and disciplinary referrals, the court denied CJA compensation. Appointed counsel performed the work and was not paid from the fund that exists to pay for it, which never shows up in a dollar-based tally.
- 4 What does a discharged show-cause order indicate? The court found no fabrication occurred The explanation was sufficient The matter was moot **Answer:** The explanation was sufficient Courts issue show-cause orders to require an explanation rather than to announce a penalty. Gamez v. County of Fresno was discharged in April 2026 with no sanction. A discharge in one case predicts nothing about another, however.
- 5 Are courts waiting for an AI-specific sanctions rule? Yes, enforcement is provisional until one arrives No, the survey concludes existing rules suffice Only the circuits are; districts are not **Answer:** No, the survey concludes existing rules suffice Each decision rests on ordinary authority, including FRAP 46(c), case removal, and conventional appellate discipline. There is no rule change to wait for, and the survey notes courts signaling that lighter sanctions may be drawing to a close.
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- **What determines how severe an AI sanction is?** On the evidence of six decisions from February to April 2026, principally what the lawyer did after being confronted. Norton Rose Fulbright's survey of those decisions identifies attorney candor as a mitigating factor and evasiveness as significantly aggravating, while noting that candor alone does not prevent sanctions. The range across those six is wide: the Sixth Circuit in Whiting v. City of Athens imposed attorneys' fees, double costs, $15,000 in punitive sanctions on each attorney and a disciplinary referral, while the Eastern District of California discharged its show-cause order in Gamez v. County of Fresno without imposing anything. The conduct that triggered them was broadly the same category. That points to the response, rather than the number of fabricated citations, as the variable doing the most work, which is also the variable most within a lawyer's control once the filing has already gone out.
- **If I admit the error immediately, will I avoid a sanction?** Not reliably, and this is the half of the finding most often dropped. The survey is explicit on both points: candor when confronted with errors is a mitigating factor, and candor alone does not prevent sanctions. What it appears to affect is where in the range an outcome falls, not whether there is an outcome at all. A fully candid lawyer may still be reprimanded, referred, and required to pay. That distinction matters for how a firm advises someone in the first hour, because framing it as "tell the court and this will be fine" sets an expectation the reported decisions do not support, and a lawyer surprised by a sanction after being honest was badly advised. The accurate framing is that candor is the cheapest available mitigation and it is not a defense.
- **What counts as evasive?** Much less than outright deception, which is why it catches people who never intended to mislead. Answering a narrower question than the one the court actually asked, describing the error without describing how it occurred, attributing it to a process rather than to a person, and delaying a correction while the firm settles on a position all read as evasive from the bench. The pattern recurs well beyond this survey: the Ninth Circuit's decision in LNU v. Blanche turned substantially on fabricated authority combined with a lack of candor about its source, and Del Biaggio v. Bansen weighed a correction that arrived more than three months after the opposing motion put counsel on notice. The structural reason evasiveness is expensive is that it converts a verification failure into a candor problem, and candor problems go to fitness rather than to carefulness.
- **A court discharged a show-cause order with no sanction. How?** In Gamez v. County of Fresno, the Eastern District of California issued an order to show cause and discharged it in April 2026 without imposing a sanction. The useful way to read that is that courts issue show-cause orders to require an explanation rather than to announce a penalty. The order is a question, and a discharge means the answer was sufficient. That reframes the task: a lawyer receiving one is answering how this happened and what has been done about it, which is answerable, rather than arguing against a penalty, which is not. What the broader findings suggest a sufficient answer contains is candor about what occurred, an account of the cause rather than the symptom, and evidence of remediation. One caution: a discharge in one case predicts nothing about another, and the same survey notes courts signaling that lighter sanctions may be drawing to a close.
- **Are courts waiting for an AI-specific sanctions rule?** No, and the survey's conclusion is that existing rules sufficiently address Gen AI misconduct. Each of the six decisions rests on ordinary authority. Fletcher v. Experian applied Federal Rule of Appellate Procedure 46(c), which allows a court of appeals to discipline an attorney for conduct unbecoming the court or for failure to comply with applicable rules, and which long predates generative AI. United States v. Farris used case removal and denial of compensation, both ordinary case-management powers. Public reprimand and admonishment are conventional appellate tools. This matches what courts have said elsewhere: the Ninth Circuit reached its conclusion through Rule 11 and inherent authority, and the Johnson v. Dunn court proceeded under inherent authority precisely because Rule 11 did not apply, without suggesting the rulebook was deficient. There is no rule change to wait for and no grace period to rely on.
- **What is denial of CJA compensation?** Under the Criminal Justice Act, counsel appointed to represent defendants who cannot afford a lawyer in federal criminal matters are compensated from public funds. In United States v. Farris, the Sixth Circuit's response included removal from the case, disciplinary referrals, and denial of that compensation. It is worth noting because it is a consequence class that appears in no tally of AI sanctions organized by dollar amount: the lawyer performed the work and was not paid from the fund that exists to pay for it. That is characteristic of this whole dataset. Across the six decisions the monetary figure is frequently the smallest component, alongside case removal, public reprimand, admonishment, double costs, the opposing party's fees, and disciplinary referrals, most of which carry no fixed number and several of which are permanent.
- **What should a firm actually do with this?** Decide the response before it is needed, because every variable that proved decisive operates after the filing. Establish in advance who is told, who investigates, who communicates with the court, and what the firm's standing instruction on candor is. Write the instruction down explicitly, because it is counterintuitive under pressure: full candor immediately, including about cause, is the position that mitigates, while partial candor that answers a narrower question than the one asked is the position that aggravates. Correct on the day you know rather than while the firm settles on a position, since delay is read as evasiveness. Bring evidence of remediation, ideally from an outside review, since that is what converts an explanation into a sufficient answer. And plan on the basis that no rule change is coming and that courts are signaling lighter sanctions are ending.

## References

- Norton Rose Fulbright. AI in litigation: Update on Gen AI sanctions in 2026. 2026. [https://www.nortonrosefulbright.com/en-us/knowledge/publications/792d8bf3/ai-in-litigation-update-on-gen-ai-sanctions-in-2026](https://www.nortonrosefulbright.com/en-us/knowledge/publications/792d8bf3/ai-in-litigation-update-on-gen-ai-sanctions-in-2026)
- U.S. Court of Appeals for the Sixth Circuit. Glenn Whiting v. City of Athens, Tenn., Nos. 25-5424 and 25-5425 (filed March 13, 2026). March 2026. [https://www.courtlistener.com/opinion/10808584/glenn-whiting-v-city-of-athens-tenn/](https://www.courtlistener.com/opinion/10808584/glenn-whiting-v-city-of-athens-tenn/)
- U.S. Court of Appeals for the Fifth Circuit. Fletcher v. Experian Information Solutions (filed February 18, 2026). February 2026. [https://www.courtlistener.com/?q=%22Fletcher+v.+Experian+Info+Solutions%22&type=o](https://www.courtlistener.com/?q=%22Fletcher+v.+Experian+Info+Solutions%22&type=o)
- Legal Information Institute, Cornell Law School. 18 U.S.C. 3006A: Adequate representation of defendants (Criminal Justice Act). 2026. [https://www.law.cornell.edu/uscode/text/18/3006A](https://www.law.cornell.edu/uscode/text/18/3006A)
- Legal Information Institute, Cornell Law School. Federal Rule of Appellate Procedure 46: Attorneys. 2026. [https://www.law.cornell.edu/rules/frap/rule_46](https://www.law.cornell.edu/rules/frap/rule_46)

Written by
## [Jamie Kloncz](https://rankshieldlegal.com/about/)
Founder, RankShield
Jamie Kloncz is the founder of RankShield, the verifiable AI and quantum security platform behind RankShield Legal. An engineer by training, he built RankShield after his own devices and business were attacked, including an AI voice-cloning scam that targeted his family, on one conviction: unverifiable security is the real danger, so every consequential action should leave a receipt anyone can independently check.
[More about Jamie →](https://rankshieldlegal.com/about/)

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