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Connecticut Court Sanctions AI Citations
Connecticut’s Supreme Court imposed sanctions after an attorney filed materials containing seven erroneous and unverified citations resulting from generative AI used in editing and review.
Bottom line: The Court treated the filings as a Rule 1.1 competence violation and imposed education, monetary and reporting sanctions.
Who this affects: The attorney and law firm in this order. The decision is a case-specific sanctions order, not a new general AI rule.
What changed: The Court imposed six additional CLE hours, two $1,000 donations, compliance reporting and reciprocal-discipline compliance.
- Case
- SC21183, TOV Realty, LLC v. Suarez.
- Authority
- Connecticut Supreme Court.
- Jurisdiction
- Connecticut.
- Status
- Sanctions order.
- Primary source
- Connecticut Supreme Court slip opinion
- Last verified
- 4 August 2026.
What did the Court find?
The Court said it was confronting for the first time a lawyer’s use of generative AI that led to submissions with fabricated or inaccurately generated citations. The attorney admitted that approximately seven citations in applications and briefs were erroneous and unverified, resulting from generative AI used in editing and review.
The attorney admitted that filing those documents violated at least Rule 1.1. The Court agreed and did not need to decide whether other conduct rules were violated.
What sanctions did the Court impose?
The attorney must complete six additional hours of CLE in ethics and law-office management, with three hours addressing generative AI. The attorney and law firm must each donate $1,000 to CT Bar Institute, Inc.
They must report compliance within six months. The attorney must also meet reciprocal-discipline obligations in any other jurisdiction of admission.
What is the practical lesson?
This order is not a substitute for the rules in another court or jurisdiction. Its practical point is narrow and concrete: a filing lawyer remains responsible for verification, even where an AI tool was used only during editing and review.
| Question | Answer |
|---|---|
| How many citation errors were admitted? | Approximately seven erroneous and unverified citations. |
| What education was ordered? | Six additional CLE hours, including three focused on generative AI. |
| Was this a new statewide AI rule? | No. It is a case-specific sanctions order. |
Before filing, verify every authority, quotation and proposition against the actual source. An AI editing step does not transfer that responsibility.
Primary source: https://www.jud.ct.gov/external/supapp/Cases/AROcr/CR355/ORD355.3.pdf
FAQ
What did Connecticut’s Supreme Court sanction?
Filing materials with approximately seven erroneous and unverified citations resulting from generative AI used in editing and review.
What sanctions were ordered?
Additional CLE, two $1,000 donations, a six-month compliance report and reciprocal-discipline compliance.
Does this order create a general AI rule?
No. It is a sanctions order in this case. Lawyers must assess the rules and orders that govern their own matter and jurisdiction.