Sixth Circuit Sanctions Attorneys over Alleged AI-Generated Fake Citations in Court Briefs

March 13, 2026

The U.S. Court of Appeals for the Sixth Circuit imposed sanctions on attorneys Van Irion and Russ Egli following suspicions of more than two dozen fabricated citations and factual misrepresentations in appellate briefs in Whiting v. City of Athens. The court raised questions about potential AI involvement, but the lawyers reportedly declined to provide a response. Public reports suggested that the submissions exhibited characteristics of AI hallucinations.

The incident underscores the importance of responsible AI use, with trustworthy AI governance becoming increasingly crucial to ensure safe and secure AI practices. Join us at HISPI Project Cerebellum TAIM to learn more about harm prevention in AI applications and how we're working towards establishing guardrails for AI.
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Alleged deployer

van-irion, russ-egli

Alleged developer

unknown-large-language-model-developers, unknown-generative-ai-developers

Alleged harmed parties

u.s.-court-of-appeals-for-the-sixth-circuit, city-of-athens-tennessee, epistemic-integrity, judicial-integrity

AI governance case studies

For forensic AI governance failure analysis (TAIMScore™ case studies), browse Human Signal’s Failure Files™.

Data source

Incident data is from the AI Incident Database (AIID).

When citing the database as a whole, please use:

McGregor, S. (2021) Preventing Repeated Real World AI Failures by Cataloging Incidents: The AI Incident Database. In Proceedings of the Thirty-Third Annual Conference on Innovative Applications of Artificial Intelligence (IAAI-21). Virtual Conference.

Pre-print on arXiv · Database snapshots & citation guide

We use weekly snapshots of the AIID for stable reference. For the official suggested citation of a specific incident, use the “Cite this incident” link on each incident page.