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Connecticut Supreme Court orders lawyer CLE after ChatGPT citation errors

Published
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22

Why it matters

The Connecticut Supreme Court sanctioned Wallingford attorney Ian Gottlieb for submitting briefs containing fabricated legal citations and quotations generated by ChatGPT. Gottlieb, who practices at GLG Law LLC, filed the defective briefs in two landlord-tenant appeals involving fair rent commission decisions in Middletown and Hartford. The court found the errors reflected negligence in AI use rather than intentional misconduct, and ordered Gottlieb to complete six additional hours of continuing legal education in ethics and law office management. Gottlieb acknowledged at the hearing that he failed to adequately review the AI-generated material before filing.

The decision marks the first Connecticut Supreme Court ruling to impose sanctions specifically for AI hallucinations in legal filings. It arrives as Connecticut courts have begun enforcing new obligations: in June 2026, the state adopted a Practice Book rule requiring all filers—attorneys and pro se litigants alike—to independently verify any AI-generated citations, legal authorities, and evidence before submission, with sanctions available for violations.

Attorneys should treat this as a clear signal that courts view AI misuse as a professional responsibility matter, not a technical problem. Connecticut's approach reflects a national trend: judges are holding lawyers personally accountable for filing accuracy regardless of whether generative AI drafted the work. The takeaway is straightforward—verification of AI output is now a nondelegable duty, and negligence in that verification carries real consequences.

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