A growing number of lawyers disciplined for misusing generative artificial intelligence are reshaping how the profession approaches continuing legal education, as judges, regulators, and firms move to close what many see as a widening competence gap.

The trend is illustrated by the case of California solo practitioner William Becker Jr., who was ordered to explain why a motion he filed appeared riddled with fictitious citations generated by AI. In response, Becker told a federal judge he had enrolled in a continuing legal education course focused on AI ethics and professional responsibility, pledging to integrate its lessons into his practice, according to Bloomberg Law.

Becker’s experience is no longer an outlier. Judges and bar leaders say the rapid spread of tools such as ChatGPT has been accompanied by a sharp rise in filings containing hallucinated cases and quotations. A Bloomberg Law analysis found that reported instances of AI misuse in litigation jumped dramatically in 2025, as generative tools became more deeply embedded in legal workflows.

The response has been swift. AI-focused CLE programs are proliferating across jurisdictions and practice settings, targeting everyone from pro se litigants and solo practitioners to lawyers at the largest firms. Federal judges have also issued standing orders and sanctions aimed at clarifying expectations around AI use in court filings.

“You must take responsibility,” Katherine Forrest, chair of Paul, Weiss’s AI group and a former federal judge, told Bloomberg Law. Submissions to the court, she said, remain the lawyer’s obligation, “not the AI.” At her firm, CLE programs emphasize long-standing duties of candor, competence, confidentiality, and supervision, reframed for an AI-enabled environment.

State bars are echoing that message. The duty of competence now requires lawyers to understand how generative AI tools function and where they fail, said Laura Enderton-Speed, executive director of the State Bar of California. Texas bar officials have similarly stressed that AI does not relieve attorneys of the obligation to verify accuracy, protect client confidentiality, or apply fair billing practices when efficiencies are gained through automation.

Large law firms are also expanding internal training, pairing risk management with instruction on using AI to improve client service. Lawyers trained on how the technology works are better positioned to assess its limitations, said Allen Waxman of DLA Piper’s AI practice, while firms such as King & Spalding are emphasizing safeguards designed to prevent ethical lapses without stalling innovation.

The consequences of getting it wrong remain tangible. In Becker’s case, a federal judge in California imposed $2,000 in sanctions for submitting AI-generated material without proper verification, citing violations of professional conduct rules. While the court did not mandate additional education, it took note of Becker’s efforts to retrain himself.