A New Jersey lawyer must pay a $5,000 sanction for a second instance in which he used made-up, AI-generated case citations in court filings, a federal district judge ruled.
Raja Rajan of Cherry Hill, NJ was unable to identify “any valid reason” for why he hadn’t verified his erroneous citations, Judge Kai N. Scott of the US District Court for the Eastern District of Pennsylvania said in a Monday order.
Scott also ordered Rajan complete additional continuing legal education courses “pertaining to artificial intelligence and legal ethics,” and provide proof of relevant CLE classes he’s already taken.
Though Rajan requested that the court issue him a “modest deterrent penalty” of $950 because of the more than $73,500 he’s paid in sactions to date, Scott said she’s unconvinced that a significantly reduced penalty for a second violation of Rule 11 of the Federal Rules of Civil Procedure “for the same conduct would adequately remedy the repeated behavior.” He was fined $2,500 for a prior instance of fake citations.
The judge said the court “remains appalled by Mr. Rajan’s improper conduct.”
The order that Rajan complete CLE is part of a growing trend from federal judges seeking to make sure lawyers who appear before them learn from AI-related ethical slips.
At the conclusion of the underlying litigation, plaintiff Mark Bunce sought travel costs for a canceled deposition. Rajan objected to the request, and Bunce subsequently alleged Rajan had for a second time used fake citations, Scott said.
Despite Rajan’s claim that a “reasonable attorney” would have filed the motion with the erroneous citations because Bunce refused to confer with him regarding the travel fee dispute, Scott said “the proper question is whether Mr. Rajan should have known that the citations in his filing were incorrect. He should have.”
She added that should Rajan engage in similar conduct a third time, she “will not hesitate” to refer him to the Pennsylvania Disciplinary Board.
Rajan didn’t immediately respond to a request for comment.
Homans Peck LLC and Miller & Martin PLLC represent Bunce. Lewis Brisbois Bisgaard & Smith LLP represents the defendants.
The case is Bunce v. Visual Tech. Innovations Inc., 2026 BL 141033, E.D. Pa., No. 2:23-cv-01740, memorandum 4/20/26.
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