A single AI hallucination in a legal brief is an incident. Two consecutive hallucinations — the second submitted after the court explicitly flagged the first — constitute a pattern, and the Third Circuit treated it as one. The sanctions against Daniel Pallen, who submitted nonexistent citations and then repeated the failure after notification, are not the legal system's first encounter with AI-generated error. They are the moment the system stopped framing these incidents as educational and started framing them as negligent. That shift in framing is what practitioners and compliance…