Holding / Framework
Sixth Circuit imposed $15,000-per-attorney punitive fines plus fee-shifting and double costs after finding fabricated citations across multiple briefs. Court explicitly justified the elevated sanction amount on the ground that 'smaller fines have plainly been inadequate, as is evidenced by the continuous stream of cases raising the same problems,' signaling escalation in appellate-level AI-hallucination sanctions.
Triggering Conduct
Counsel cited 24+ fake citations across appellate briefing, including citations whose Federal Reporter references actually corresponded to two unrelated 10th Circuit cases (one on unfair competition, one on a guilty plea), neither addressing the propositions cited. Citations also lacked the language quoted in the brief and failed to support the propositions advanced. Both attorneys had prior discipline for lack of candor to the tribunal; misconduct spanned three cases.
Sanctions / Disposition
$15,000 each in punitive fines to court registry against attorneys Van R. Irion and Russ Egli ($30,000 total, reportedly the largest federal appellate AI-related sanction as of March 2026), plus joint responsibility for appellees' full attorney fees on appeal and double costs.
Primary Source
https://www.lawnext.com/2026/03/sixth-circuit-slaps-steep-sanctions-on-two-lawyers-for-fake-citations-and-misrepresentations-in-appellate-briefs.html · secondary_aggregator (LawSites); primary opinion pull pending
Tags
circuit_court, hallucinated_citations, large_sanction, repeat_misconduct, attorney, escalation_signal