Law360 (August 3, 2026, 2:02 PM EDT) -- The Connecticut Supreme Court has ordered a GLG Law LLC attorney to complete continuing education after finding that seven errors in filings caused by ChatGPT stemmed from negligence in the use of new technology, not from an intentional attempt to deceive or mislead the court.

In a Friday per curiam order, the Connecticut Supreme Court said attorney Ian G. Gottlieb shall complete six hours of continuing legal education in the areas of ethics and law office management, three hours of which must concern the use of generative artificial intelligence, in addition to the 12 mandatory CLE credit hours each Connecticut lawyer must earn every calendar year.

Gottlieb and GLG Law were also ordered to each donate $1,000 to the CT Bar Institute Inc. to support its work to provide the legal profession with instruction in the areas of legal ethics and law office management, and regarding the role of generative AI in those areas, the high court said.

"Our client has owned his mistakes since this happened, is grateful that this matter has concluded, and that the court has meted out a fair and balanced sanction," James F. Sullivan and Noah J. Kores of Logan Vance Sullivan & Kores LLP, counsel for GLG Law and Gottlieb, told Law360 Pulse on Monday. "We hope this case is instructive to the bar and the public so that others can avoid making the same errors with this new and evolving technology."

This matter was the first time the Connecticut Supreme Court said it was required to confront a lawyer's use of generative AI that resulted in written materials being submitted to the high court containing citations that were "hallucinated."

Gottlieb had filed briefs in two cases that contained approximately seven erroneous and unverified citations as a result of the use of ChatGPT, the order states. At a July 7 show cause hearing, Gottlieb admitted that his conduct violated, at a minimum, Rule 1.1 of the Rules of  Professional Conduct, according to the order.

While apologizing to the court during the hearing, Gottlieb said he manually researched and drafted his arguments, then used Shepard's Citations Service, a LexisNexis product, to ensure that the cases he cited had not been overturned. He then said he copied and pasted his draft into ChatGPT to improve his writing.

"Unfortunately, it did quite the opposite," Gottlieb said. "It made changes that I did not notice, including adding quotations and changing citations."

He missed the errors in a subsequent review, Gottlieb continued. Although he admitted that multiple citations and quotations were wrong, "the propositions of law themselves were not," he told the justices. "That's one of the reasons that the changes did not pop out to me."

He said subsequent investigations did not uncover precisely when the errors were introduced during the editing process.

In Friday's order, the Connecticut justices said that in determining discipline in this case, they were mindful that Gottlieb didn't intentionally try to deceive or mislead the court or other parties, but that the errors came from negligence in the use of new technology.

"Attorney Gottlieb did not have a dishonest or selfish motive, he cooperated with the disciplinary process by honestly and forthrightly responding to our requests seeking further information and understanding regarding the erroneous citations, he admitted his mistake, he showed sincere contrition, and he has no disciplinary history," the order states. "Nevertheless, the submission of erroneous citations in violation of the Rules of Professional Conduct is not something we take lightly."

Both Gottlieb and the firm also have to file a report with the court, along with a courtesy copy to the Statewide Grievance Committee, stating that they have complied with the sanctions within six months and Gottlieb shall comply with the reciprocal discipline obligations of any other jurisdiction he's admitted to practice law in, the order states.

The order added that the copy provided to the Statewide Grievance Committee is not a referral for further disciplinary action.

At July's show cause hearing, Sullivan said Gottlieb should be forced to take six additional hours of continuing legal education in addition to the mandatory CLE credit hours required annually. He also said a $250 fine for the lawyer and the firm would also be appropriate, paid either to the court or to a charity.

The justices also said that in arriving at their decision, they weren't rejecting the use of new and improved technologies in the legal profession.

"Instead, we emphasize that all legal professionals must be acutely aware of the risks and dangers that accompany these technologies, and attorneys must take all steps necessary to ensure that such innovations are utilized with the utmost care and attention to their professional obligations," the justices wrote.

They also pointed to new Connecticut state court rules published in June requiring attorneys and self-represented parties to verify AI output. In mid-July, the Connecticut Appellate and Supreme Courts adopted amendments to the Rules of Appellate Procedure to address concerns regarding the use of generative AI in court filings.

"This order should serve as a reminder to all members of the legal profession to learn about the risks and limitations of the technologies they use in the practice of law because they remain personally responsible to make certain that all information submitted to the court is true and accurate," the justices wrote.

Gottlieb and GLG Law are represented by John Logan, James F. Sullivan and Noah J. Kores of Logan Vance Sullivan & Kores LLP.

The cases are Kosel Equity LLC v. Mark MacGregor et al., case number SC 21184, and TOV Realty LLC v. Angel Suarez et al., case number SC 21183, both in the Connecticut Supreme Court.

--Additional reporting by Aaron Keller and Brian Steele. Editing by Karin Roberts.

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