Courts on AI / Fabricated or misquoted citations

Matter of Julien v. Arthur

Supreme Court of the State of New York, Appellate Division, Second Department · State appellate courts · NY · 2026-05-28 · 2026 N.Y. Slip Op. 03308 · No. 2024-03307 · opinion

Fabricated or misquoted citations

On 2026-05-27, in In the Matter of Kevin A. Julien v. Danielle M. Arthur, New York's Second Department imposed a $250 sanction on the self-represented appellant for a brief prepared with unverified generative AI. A self-represented appellant filed an appellate brief using unsupported or inaccurate legal authorities.

Disposition: The court affirmed the custody order and imposed a $250 sanction payable to the Clerk of the Court for transmittal to the Commissioner of Taxation and Finance.
Recorded conduct: The pro se father filed an appellate brief with a fictitious case and placeholder text reflecting GenAI use. The court imposed a $250 sanction and cautioned that future misuse could produce greater sanctions. — outcome: fine; actor: litigant in person; $250
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.

By order to show cause datedJanuary14,2026,thisCourtdirectedthepartiestoshow cause before this Court why an order should not be made and entered imposing sanctions and/or costs, if any, as this Court may deem appropriate, against the appellant pursuant to 22 NYCRR 130–1.1 for filing a brief containing fabricated legal authority. The motion was held in abeyance and referred to the panel of Justices hearing the appeal for determination upon the argument or submission thereof. Kevin A. Julien, Brooklyn, NY, appellant pro se. Geanine Towers, Brooklyn, NY, for respondent. WOOTEN, J. This appeal presents this Court with the opportunity to address an emerging issue with broad and significant implications—the usage of generative artificial intelligence(hereinafterGenAI)indraftingappellatebriefs— which has the potential to produce misleading or inaccurate information,includingcitationstononexistentcases.Wehold that the unverified usage of GenAI to draft an appellate brief containing false information constitutes frivolous conduct warranting the imposition of a sanction, even when the offending party is a pro se litigant. COLLEEN D. DUFFY, J.P. PAUL WOOTEN CARL J. LANDICINO SUSAN QUIRK, JJ. Argued—January 8, 2026 OPINION & ORDER *1 I. Relevant Factual Background The parties, who were never married, are the parents of a child, born in June 2020.

Authorities cited in the passage: 22 NYCRR 130–1.1

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).

United States court documents are public domain; the topic coding, disposition line and summary are SafeLegalAI's reading of the document for comparison, not a finding about any person named in it. This record summarises a public court document or official publication and reports what it says; SafeLegalAI makes no findings of its own. Individuals and organisations are named only as they appear in that public record. Anyone named may send a right of reply, correction or contextual update (for example an appeal, vacatur or later disposition) via /report; we add a dated note where appropriate. Reply or correct this record.

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub