Kusmin L. Amarsingh v. Frontier Airlines, Inc.
10th Cir. CA · Feb 9, 2026
What happened in this matter?
The 10th Circuit sanctioned attorney Kusmin L. Amarsingh for using ChatGPT to generate fabricated case law and misattributed quotations in an appellate brief. The court imposed a $1,000 monetary sanction to cover the opposing party's fees and referred the attorney to the Maryland disciplinary authority.
- Why the court cared
- Fabricated: Case Law | Brief contained seven case citations that the court could not locate; court ordered appellant to produce accurate copies or explain and concluded they were fabricated by ChatGPT. || False Quotes: Case Law | Appellant attributed propositions or quotations to a real case that did not contain the quoted language or stand for the cited proposition; court determined the attribution was inaccurate and resulted from AI output. || False Quotes: Case Law | A second instance where appellant attributed a quotation or proposition to an actual opinion that did not contain that material; court treated this as an AI-produced misquote and part of the reckless failure to verify authorities. || Fabricated: Case Law | Appellant's brief included seven case citations that the court could not locate; court determined they were fabricated outputs of ChatGPT. || False Quotes: Case Law | Appellant attributed propositions and quotations to two real cases that did not contain those propositions or quotations; court found the attributions inaccurate.
- Why it matters now
- Consumer ChatGPT output in an appellate brief triggers bar referral regardless of sanction size; ban it firmwide.
Why this matter is tracked
The 10th Circuit Court of Appeals sanctioned attorney Kusmin L. Amarsingh for including seven fabricated case citations and multiple misattributed quotations in her appellate brief, which she admitted were generated by ChatGPT. The court determined that Amarsingh failed to perform the fundamental duty of verifying the existence and accuracy of legal authorities. While the court declined to dismiss the appeal, it found the conduct reckless and frivolous under Federal Rule of Appellate Procedure 38. Consequently, the court ordered Amarsingh to pay $1,000 to the appellee to offset attorney fees and directed the Clerk’s Office to refer her to the Maryland attorney-disciplinary authority for further review of her professional conduct.
Consumer ChatGPT output in an appellate brief triggers bar referral regardless of sanction size; ban it firmwide.
Record details
What the record establishes about AI use
The appellant admitted to using ChatGPT.
Appellate review of a district court's Rule 12(b)(6) dismissal, combined with a court-initiated show-cause proceeding regarding sanctions for AI-generated misrepresentations.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
5 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Brief contained seven case citations that the court could not locate; court ordered appellant to produce accurate copies or explain and concluded they were fabricated by ChatGPT.
- False Quotes: Case Law | Appellant attributed propositions or quotations to a real case that did not contain the quoted language or stand for the cited proposition; court determined the attribution was inaccurate and resulted from AI output.
- False Quotes: Case Law | A second instance where appellant attributed a quotation or proposition to an actual opinion that did not contain that material; court treated this as an AI-produced misquote and part of the reckless failure to verify authorities.
- Fabricated: Case Law | Appellant's brief included seven case citations that the court could not locate; court determined they were fabricated outputs of ChatGPT.
- False Quotes: Case Law | Appellant attributed propositions and quotations to two real cases that did not contain those propositions or quotations; court found the attributions inaccurate.
Questions this record answers
- What happened in Kusmin L. Amarsingh v. Frontier Airlines, Inc.?
- The 10th Circuit sanctioned attorney Kusmin L. Amarsingh for using ChatGPT to generate fabricated case law and misattributed quotations in an appellate brief. The court imposed a $1,000 monetary sanction to cover the opposing party's fees and referred the attorney to the Maryland disciplinary authority.
- Why does Kusmin L. Amarsingh v. Frontier Airlines, Inc. matter for legal AI risk?
- Consumer ChatGPT output in an appellate brief triggers bar referral regardless of sanction size; ban it firmwide.
- What does the public record establish about Kusmin L. Amarsingh v. Frontier Airlines, Inc.?
- Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
- Which source supports this Kusmin L. Amarsingh v. Frontier Airlines, Inc. summary?
- The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.
Related matters
Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.