Holding / Framework
Court imposed escalating monetary sanction ($5,000, doubled from prior $2,500) against attorney for repeat filing of AI-hallucinated briefs and warned that a third instance would trigger referral to the attorney's licensing-state disciplinary board. Notable for the cross-jurisdictional disciplinary escalation framework: federal court in non-licensing state imposes monetary sanction and signals referral to the state where the attorney is admitted.
Triggering Conduct
Cherry Hill, NJ attorney Raja Rajan filed brief containing AI-hallucinated citations in federal civil matter. Second instance of same conduct after prior $2,500 sanction. Rajan stated he had not litigated cases in years and picked up the matter to assist his brother and former business partner who was accused of deceiving an investor for a million-dollar loan.
Sanctions / Disposition
$5,000 (April 2026, second sanction against Rajan for AI-hallucinated brief content). Prior sanction of $2,500 imposed for first instance. Court warned that a third instance would result in referral to the Pennsylvania disciplinary board (Rajan is licensed in PA, not NJ; appeared in NJ federal court on a non-litigation-practice basis to assist his brother).
Primary Source
https://www.inquirer.com/news/new-jersey/ai-legal-research-court-filings-halluciations-sanctions-court-20260427.html · secondary_aggregator (Philadelphia Inquirer / Bloomberg Law); primary docket pull pending
Tags
3d_circuit, hallucinated_citations, repeat_offender, escalation, cross_jurisdiction_referral, attorney, low_practice_volume