Tracked Changes, Friday, September 11, 2026
New Mexico Supreme Court holds a lawyer in direct contempt over a ChatGPT brief with invented witnesses
On September 9, the Supreme Court of New Mexico found attorney Stephen D. Aarons in direct contempt in State v. Sandoval, a criminal appeal, according to the AI Hallucination Cases database. He admitted using ChatGPT and not verifying the brief, which invented four witnesses and testimony and misstated two precedents. The court struck the brief, referred him to the Disciplinary Board, barred him from appearing before it pending proceedings and ordered a $5,000 payment.
New York court dismisses a petition drafted with Spellbook and awards $15,000 in sanctions and fees
In Youssian v. Village of Kings Point, decided September 9, a New York court struck an Article 78 petition and its amended version and dismissed the case, the database says. Counsel used Spellbook AI to draft papers that misquoted or misstated four cases, and first denied the errors. The court imposed a $5,000 frivolous-conduct sanction and ordered $10,000 in fees and costs to the respondents.
Indiana federal court sanctions counsel $10,000 for eleven nonexistent case citations
On September 11, the Southern District of Indiana personally sanctioned counsel $10,000 under Rule 11 in Virgil v. Experian Information Solutions, a consumer credit case, adopting a magistrate judge's recommendation. The court counted eleven nonexistent and four inaccurate citations across five filings, the last filed seven days after the defendants first raised concerns. Counsel did not cite AI use, but admitted he failed to make a reasonable inquiry.
Harvey raises $550 million at a $15.5 billion valuation and buys AI agent security firm Guardrails AI
Harvey announced on September 9 a $550 million round at a $15.5 billion valuation, co-led by Diffusion and Lightspeed Venture Partners. Artificial Lawyer reports that Harvey also acquired Guardrails AI, a San Francisco company whose tools detect when AI agents deviate from intended behavior, and calls it Harvey's fourth acquisition of 2026. Harvey says 80% of Am Law 100 law firms use Harvey.