TOV Realty, LLC v. Suarez

Summary

In a per curiam order spanning two dockets, the Supreme Court of Connecticut imposed sanctions on Attorney Ian G. Gottlieb and his firm, GLG Law, LLC, for filing public interest appeal applications and briefs containing approximately seven hallucinated—fabricated or inaccurately generated—citations introduced when ChatGPT was used to edit and review otherwise verified drafts. The court agreed with Gottlieb's concession that filing documents with erroneous, unverified AI-generated citations violated rule 1.1 of the Rules of Professional Conduct (duty of competent representation), consistent with what it described as uniform federal and state authority. Balancing aggravating and mitigating factors—including that the errors stemmed from negligence rather than an intent to deceive, Gottlieb's cooperation, admission, and contrition, his clean disciplinary history, and the firm's failure to maintain policies on responsible generative AI use—the court ordered targeted continuing legal education, $1,000 donations to the CT Bar Institute by each respondent, a six-month compliance report, compliance with reciprocal discipline obligations, and public posting of the order.