The Connecticut Supreme Court has issued a noteworthy decision reinforcing that attorneys remain fully accountable for the accuracy of their filings, even when generative…
The Connecticut Supreme Court has issued a noteworthy decision reinforcing that attorneys remain fully accountable for the accuracy of their filings, even when generative artificial intelligence plays a role in the drafting process. The court ordered attorney Ian G. Gottlieb of GLG Law LLC to complete continuing legal education after seven hallucinated citations appeared in briefs he submitted to the court. The ruling stands as an important reminder that the responsibilities imposed by the Rules of Professional Conduct extend to every tool a lawyer chooses to employ.
At a show cause hearing held on July 7, 2026, Gottlieb acknowledged that the fabricated citations were the product of ChatGPT use during the editing and review of his briefs. The court examined the circumstances surrounding the submissions and concluded that the errors reflected negligence rather than any intent to deceive the tribunal. On that basis, the court declined to impose a stricter sanction and instead directed Gottlieb to complete continuing legal education addressing the responsible use of technology in legal practice.
Central to the court's analysis was Rule 1.1 of the Rules of Professional Conduct, which governs the duty of competence. The court found that the negligent use of generative AI during the editing and review process fell short of the diligence and care required of attorneys practicing in Connecticut. In doing so, the court sent a clear signal that competence in the modern practice of law includes a working understanding of the limitations of the technologies attorneys rely upon, particularly those prone to producing plausible but inaccurate output.
For clients and law firms alike, the decision underscores several important themes. Courts across the country are increasingly attentive to the risks posed by generative AI in legal work, and negligence in verifying AI-generated content can carry professional consequences even absent bad faith. Firms should ensure that internal protocols require rigorous independent verification of any citation, quotation, or authority produced with the assistance of AI tools. A measured, well-supervised approach to these technologies remains essential to protecting both client interests and professional standing.
This article is provided for general informational purposes only and does not constitute legal advice. Clients facing specific questions about the use of generative AI or professional conduct obligations should seek tailored guidance from qualified counsel.