Judge Sanctions Lawyer for AI-Generated False Citations in Court Filing

Federal Judge Sanctions Lawyer for Misusing AI in Legal Filings

In a scathing order issued on March 11, 2026, Judge Kai Scott of the U.S. District Court for the Eastern District of Pennsylvania sanctioned attorney Mr. Rajan in the case Bunce v. Visual Tech. Innovations, Inc. The ruling comes after Rajan repeatedly filed motions containing false legal citations, including at least one entirely fabricated case.

Background of the Sanction

Plaintiff’s counsel sought reasonable travel costs for a cancelled deposition. In response, Rajan filed an omnibus motion opposing the request and seeking sanctions. The plaintiff’s response highlighted Rajan’s prior sanction for similar misconduct, noting that he had again used a "made-up case" and cited authorities that did not support his arguments.

In his reply, Rajan addressed the issue only in a brief footnote. The court then ordered him to pay all reasonable travel costs, deny his omnibus motion, and explain why his citations did not violate Rule 11(b) or the court’s Standing Order Re: Artificial Intelligence.

Court Rejects Rajan’s Defenses

In his response to the court’s Order to Show Cause, Rajan argued that a "reasonable attorney" would have acted similarly under the circumstances. He claimed opposing counsel’s refusal to confer on travel fees justified his use of erroneous citations. The court firmly rejected this reasoning.

"The proper question is not whether a reasonable attorney would have acted similarly, but whether Mr. Rajan should have known his citations were incorrect."

— Judge Kai Scott, U.S. District Court, E.D. Pa.

The court emphasized that Rule 11(b) requires attorneys and pro se litigants to verify the accuracy of all filings before submission. Rajan’s failure to do so—despite claiming he "haphazardly" submitted an AI-generated document without verification—was deemed inexcusable.

Court Cites Multiple Failures in Rajan’s Conduct

The court outlined several key failures in Rajan’s conduct:

• No verification of citations: Rajan admitted he did not verify the accuracy of the citations in his filings.
• Fabricated case: At least one citation referenced a non-existent legal authority.
• Deflection and blame-shifting: Rajan attempted to shift responsibility to opposing counsel, arguing that their refusal to meet justified his actions.
• Misinterpretation of AI rules: Rajan claimed the court’s Standing Order did not clearly require "human verification only."
• Lack of valid justification: Rajan could not provide a reasonable explanation for his failure to verify citations, stating he does not normally practice law.

The court also noted that Rajan could have requested an extension of time to properly research and verify his citations—a request the court stated would have been readily granted.

Court’s Final Ruling

Judge Scott concluded that Rajan’s conduct was unreasonable and violated professional standards. The court ordered him to pay the plaintiff’s reasonable travel costs and directed him to show cause why he should not face further sanctions for violating Rule 11(b) or the court’s AI Standing Order.

"It was not enough that Mr. Rajan felt like he had no other choice because opposing counsel refused to meet with him. He could have requested an extension of time, which the Court would have readily granted."

— Judge Kai Scott

The case serves as a stark reminder of the ethical obligations attorneys face when using AI tools in legal practice. Courts are increasingly scrutinizing the accuracy and integrity of AI-generated content in legal filings, emphasizing the need for human oversight and verification.