Jason M. Hatfield, P.A. v. Pirani
Court sanctionU.S. District Court, Western District of Arkansas · W.D. Ark. · Decided December 4, 2025
- Citation:
- Jason M. Hatfield, P.A. v. Pirani, No. 5:22-CV-5110 (W.D. Ark.)
- AI tool:
- ChatGPT
- Sanction amount:
- $1,578,172 attorney fees + $93,388 costs
What happened
Attorney Tony Pirani (Pirani Law, Fayetteville) used ChatGPT to draft post-trial motions. The filings contained citations to nonexistent cases and quotations from nonexistent passages. Pirani electronically signed and filed the documents. He admitted the AI use at a pretrial conference on 2025-07-11; Judge Timothy L. Brooks issued an order to show cause on 2025-07-31.
Outcome
$1,578,172 in additional attorney fees and $93,388 in costs awarded to opposing party. Pirani was also referred to the Arkansas Judiciary's Office of Professional Conduct. Judge Brooks stated the sanctions were intended not only to address Pirani's conduct but also 'to deter similar misconduct by other attorneys practicing in the Western District of Arkansas, particularly with respect to the uncritical use of artificial intelligence in court filings.' The largest known dollar-amount AI-hallucination sanction in the United States to date.
Hatfield v. Pirani is the largest AI-hallucination sanction in the country by dollar amount. The number itself is a signal: when a court wants to deter a category of conduct, it does not calibrate the sanction to the individual. Judge Brooks said so explicitly. The case also illustrates the downstream risk of unverified AI drafting — the sanctioned conduct was in post-trial motions, where a fee-shifting posture amplified the exposure.
Primary sources
Last verified: April 24, 2026. Verify against primary sources before relying on this in a filing.