Kusmin L. Amarsingh v. Frontier Airlines, Inc.
10th Cir. CA · Feb 9, 2026
- Jurisdiction
- federal
- Court
- 10th Cir. CA
- Record ID
- kusmin-l-amarsingh-v-frontier-airlines-inc-2026-02-09
- Observed outcome
- The court affirmed the district court's dismissal, imposed a $1,000 monetary sanction payable to the appellee, and ordered a referral to the Maryland attorney-disciplinary authority.
- Known monetary consequence
- $1,000
Why this matter warrants attention
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.
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.
Consumer ChatGPT output in an appellate brief triggers bar referral regardless of sanction size; ban it firmwide.
Failure modes and consequences
- Fake Citations
- Fabricated Quotes
- Bar Referral
- Civil Rights
- Appellate
- Monetary
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- $1,000
- Procedural posture
- 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.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The appellant admitted to using ChatGPT.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Use only approved research and drafting tools for legal work.
- Retain a matter-level record of source checks and corrections.