Courts on AI / Fabricated or misquoted citations

Yaroshevsky v. Karlin

United States District Court for the Eastern District of New York · Federal district courts · NY · 2026-02-23 · 2026 WL 522624 · No. 25-CV-2747 (DG) (SDE) · report and recommendation

Fabricated or misquoted citationsGoogle Gemini

On 2026-03-31, U.S. District Court for the Eastern District of New York recommended an adverse fee award after finding Rule 11 safe-harbor compliance and repeated nonexistent or misrepresented AI-generated authorities. A self-represented party submitted a complaint with multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Ramirez v. Humala, 24-CV-242.

Disposition: The magistrate judge recommended denying plaintiff leave to amend, granting Rule 11 sanctions including dismissal with prejudice, alternatively granting defendants' motion to dismiss with prejudice, and allowing defendants to apply for fees related to the sanctions motion.
Recorded conduct: Plaintiff's complaint and other filings contained repeated false and misleading citations, including at least seven nonexistent cases in the complaint, five nonexistent cases in his motion-to-dismiss opposition, and eight cases in his sanctions opposition that did not support the cited proposition or lacked the quoted language; he admitted using Google Gemini for some citations and not verifying them. — outcome: pending; actor: litigant in person
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.

claims with prejudice. nonexistent legal authority or misrepresenting the import of legal authority resulting from a lack of effort to verify the content of AI-generated drafts is sanctionable. See, 1. Defendants Met Rule 11’s Procedural Requirements e.g., Ramirez v. Humala, 24-CV-242, 2025 WL 1384161, at *1 (E.D.N.Y. May 13, 2025) (listing cases addressing The undersigned first considers whether Defendants met the AI-generated citations and finding “the Second Circuit, as safe harbor notice requirement of Rule 11 and concludes well as district courts across the country, have found the that they have. As previously discussed, Defendants served submission of nonexistent case citations in filings to the a copy of their motion on Plaintiff 21 days before moving court to constitute sanctionable conduct under Rule 11(b) for sanctions. 4 See supra pp. 7–8. The undersigned finds (2).”); Ferris v. Amazon.com Services, LLC, 24-CV-304, 2025 this provided Plaintiff with the requisite notice to correct the WL 1122235, at *2 (N.D. Miss. Apr. 16, 2025) (imposing alleged misconduct prior to Defendants seeking sanctions. sanctions against pro se plaintiff who continued to submit EVGENY YAROSHEVSKY, Plaintiff, v. BENJAMIN W. KARLIN,..., Slip Copy (2026) false citations

Authorities cited in the passage: Ramirez v. Humala, 24-CV-242, 2025 WL 1384161

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: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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