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 · 2026-05-14 · No. 2026-01135; 2026-00170 · opinion

Fabricated or misquoted citationsChatGPT

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 attorney was suspended from the practice of law, with the AI-related drafting misconduct discussed as part of the disciplinary record.
Recorded conduct: The disciplinary decision described an underlying filing drafted with ChatGPT or similar AI that contained numerous nonexistent authorities. The court imposed a suspension. — outcome: suspension; actor: lawyer
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.

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Read from the copy held by Damien Charlotin's AI Hallucination Cases Database (CC BY 4.0) of the court-authored document. court site blocks automated access (checked www.nycourts.gov) Official copy not obtained 2026-09-08: court site blocks automated access (checked www.nycourts.gov) (checked www.nycourts.gov). Re-coded from the document 2026-09-08 (independent second read).

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