Texas Attorney Sanctioned Over AI-Generated Citations in Filing

A Texas attorney was sanctioned for including inaccurate citations generated by artificial intelligence in a motion filing, according to a Texas state judge.

Lawrence Chang must pay $2,000 in attorneys’ fees and expenses to opposing counsel at Rusty Hardin & Associates LLP and write a letter outlining where his AI use erred and how he’ll avoid doing so in the future, Judge Maya Guerra Gamble said in an order Wednesday. Guerra Gamble granted the opposing counsel’s motion to sanction Chang, who works for Choate & Associates PC.

The court finds “good cause supports the imposition of sanctions in order to deter such conduct in the future, which amounts to serious misconduct that threatens to impugn the integrity of the courts and the administration of justice,” Guerra Gamble said.

Chang represents an acupuncture business alleging legal malpractice claims against prominent Texas attorney Dan Cogdell. The business alleges Cogdell never got permission to negotiate a $2.3 million settlement with the federal government to resolve claims they over billed the US Department of Veteran Affairs.

Chang responded with a motion for reconsideration, which included the bogus citations. As part of his sanction, Chang’s reconsideration motion was struck.

The sanctioned attorney admitted to using AI and not checking the veracity of the citations it spit out in a Sept. 23 filing. Chang mistakenly initially blamed the error on an “over-reliance” on a research tool in WestLaw but later realized it stemmed from pasting his draft into ChatGPT’s legal tool to improve his writing, the attorney said.

Some of the cases he cited from WestLaw were altered when ChatGPT changed his citations and included references not initially there, Chang said. He contends the underlying legal arguments he made, despite differing from their citations, are warranted by existing law.

Chang joins many other attorneys who have been hit with sanctions and fines over the use of “AI-hallucinated” citations in their filings over the past few years. A California federal judge in September imposed a $1,500 sanction on an attorney alleged to have used artificial intelligence to generate more than a dozen fictitious case citations in a filing earlier this year.

The case is Ma v. Cogdell Law Firm PLLC, Tex. Dist. Ct., No. D-1-GN-25-001604, 10/22/25.