Courts on AI / Fabricated or misquoted citations
Evgeny Yaroshevsky v. Karlin et al.
U.S. District Court for the Eastern District of New York · Federal district courts · NY · · 2026 WL 522624 · No. d 02/23/2026 cottages on the North Shore · other
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 court recommended an adverse fee award after finding Rule 11 safe-harbor compliance and repeated nonexistent or misrepresented AI-generated authorities.
- Recorded conduct
- The complaint used multiple false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Ramirez v. Humala, 24-CV-242, which the court found nonexistent, misquoted, or unsupported. — outcome: costs order; 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
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