Supreme Court of Connecticut

TOV Realty, LLC v. Suarez (SC 21183) and Kosel Equity, LLC v. MacGregor (SC 21184)

Sanctioned · 31 July 2026

SectorLegal

CountryUnited States

Document typeApplications for certification and appellate briefs in two public interest appeals

ConsequenceSanctioned

What was fabricated

Approximately 7 erroneous and unverified citations across applications for certification and briefs in two appeals. Attorney Ian G. Gottlieb researched using LexisNexis and verified every quotation and citation through Shepard's Citations Service — then pasted the verified drafts into ChatGPT to improve organisation and quality. ChatGPT added new case citations and altered existing ones. The hallucinations did not change the legal propositions, which remained correct, so no one re-verified. The errors were caught by amici curiae represented by the Jerome N. Frank Legal Services Organization, not by the firm.

What happened as a result

Per curiam order of 31 July 2026. Attorney Gottlieb must complete 6 hours of continuing legal education in ethics and law office management (3 of which must concern generative AI) on top of the 12 hours required annually. Gottlieb and GLG Law, LLC must EACH donate $1,000 to the CT Bar Institute, Inc. Both must file a compliance report within six months, with a courtesy copy to the Statewide Grievance Committee. Gottlieb must comply with reciprocal discipline obligations in every other jurisdiction where he is admitted. The order is posted on the Judicial Branch website. Errata sheets and corrected briefs were filed. The court found a rule 1.1 (competence) violation but expressly found no intention to deceive. The law firm was held to share responsibility for having had no generative-AI policy at the time.

Sources

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