Courts on AI / Fabricated or misquoted citations
In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law
Supreme Court of New York, Appellate Division, First Department · State appellate courts · NY · · No. 2026-01135; 2026-00170 · order
On 2026-05-14, in In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law, New York's First Department suspended the attorney for three months and imposed a $1,500 sanction for filing an AI-hallucinated judicial-order draft. Counsel filed a brief using numerous nonexistent or hallucinated authorities.
- Disposition
- The court suspended the attorney for three months and imposed a $1,500 sanction for filing an AI-hallucinated judicial-order draft.
- Recorded conduct
- Counsel filed a brief using numerous nonexistent or hallucinated authorities. — outcome: sanctions; actor: lawyer; $1,500
- Canonical record
- Incident tracker entry — verified outcome, regulator disposition and related rules
What the court wrote
Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.
Respondent’s draft, however, was replete with citations to non-existent cases attributed by the court to hallucinations by ChatGPT or a similar artificial intelligence program. Complainant was fined $1,500 and ordered to contact the internet platform, self-report their sanction, and report respondent to the New York disciplinary authorities. In furtherance of the AGC’s investigation, on October 3, 2025, the AGC and respondent agreed to November 6, 2025 as the date for respondent’s virtual examination under oath (EUO). However, on October 6, 2025, respondent informed the AGC that she would not be appearing for the scheduled EUO because the AGC’s investigation was “a racist attack and a form of racial and gender harassment.” The AGC then sought respondent’s consent to serve her with a judicial subpoena via email. The subpoena directed respondent to appear for a virtual EUO and to produce specified records.
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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