The Nebraska Supreme Court suspended Omaha attorney Greg Lake from practising law on April 15, 2026, after a divorce case appeal brief he submitted contained 57 defective citations out of 63, including 20 entirely fabricated case references and four cases that do not exist in any jurisdiction.
How the errors were discovered
Lake filed the appeal brief on behalf of the husband in a divorce case disputing the effective date for dividing marital assets and child custody. The day after filing, he submitted a replacement brief but made no attempt to correct any questionable contents. It was the opposing attorney who flagged the brief’s problems, noting fictitious citations, citations to real cases with incorrect holdings, and invented quotations. The Nebraska Supreme Court justices questioned Lake directly at oral argument in February 2026. When asked whether he had used AI, Lake said no, attributing the errors to filing a draft version while his computer had broken during his wedding anniversary trip.
The court dismissed the appeal and referred Lake to the Nebraska Counsel for Discipline, stating his explanation lacked credibility. The Counsel recommended temporary suspension on April 9. The Supreme Court issued the suspension on April 15.
What the brief contained
Of 63 citations, 57 contained some form of defect. Twenty were hallucinations: realistic-seeming but entirely fabricated references. Four cited cases do not exist in any jurisdiction. The remainder cited real cases with incorrect holdings, including one where a quotation used to argue for joint custody came from a case that contained no such proposition and did not address the matter at all. The court noted the errors could have been caught using standard legal research platforms.
The broader picture
Lake’s suspension is the most severe professional sanction handed down in the United States to date for AI-related filing errors, escalating consequences from financial penalties to career suspension. Researcher Damien Charlotin at HEC Paris, who maintains a global database of AI hallucination cases in legal proceedings, now tracks more than 1,200 such cases worldwide, approximately 800 from US courts. He has described the pace as reaching ten cases from ten different courts on a single day.
US courts imposed at least $145,000 in sanctions against attorneys for AI citation errors in the first quarter of 2026 alone. Oregon holds the largest single-attorney aggregate at $109,700. The Sixth Circuit issued a $30,000 fine against two Tennessee attorneys, the largest federal appellate sanction yet tied to fabricated citations. Nebraska’s indefinite suspension is the first to remove a practitioner from the bar entirely over AI-related errors.
John Moore is the editor of fastai.news, an independent publication covering developments in artificial intelligence.
He founded fastai.news in April 2026 to apply the same rigorous, neutral reporting standards he established at Powerboat News – his international publication – to the fast-moving world of AI.
With no filler and no opinion, fastai.news reports what is happening in AI models, research, business and tools, and leaves readers to draw their own conclusions.
John is based in Buckinghamshire, England.