Courts on AI / Fabricated or misquoted citations
In the Matter of Kevin A. Julien v. Danielle M. Arthur
Supreme Court of New York, Appellate Division, Second Department · State appellate courts · NY · · 2026 WL 1476261; 2026 N.Y. Slip Op. 03308 · No. (Docket Nos. V-4283-21,V-4283-21/23B · opinion
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 imposed a $250 sanction on the self-represented appellant for a brief prepared with unverified generative AI.
- Recorded conduct
- A self-represented appellant filed an appellate brief using unsupported or inaccurate legal authorities. — outcome: sanctions; 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
compiled by the Cognesio LLP editorial teammethodas of 2026-09-07v0.1.1coding CC BY 4.0JSON Hugging Face GitHub
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