Courts on AI / Fabricated or misquoted citations
Superb Motors Inc. v. Anthony Deo
United States District Court for the Eastern District of New York · Federal district courts · NY · · No. 23-CV-6188 (JMW) · order
The Eastern District of New York on 2026-04-30 ordered counsel to pay $1,500 for filing unverified or fabricated authorities in Superb Motors Inc. et al. v. Anthony Deo et al. Counsel filed a submission with two fabricated case citations, including In re Marcus, 491 F.2d 56, 60 (2nd Cir. 1974).
- Disposition
- The court imposed a $1,500 sanction payable into the court registry and declined to refer the matter to the grievance committee.
- Recorded conduct
- Attorney Harry Thomasson, appearing pro se, filed an opposition with two fake citations, In re Amica and In re Marcus, generated by or consistent with generative AI. The court imposed a $1,500 court-registry sanction. — outcome: fine; actor: lawyer; $1,500
- 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.
...Ste Box 112 Wantagh, NY 11793 Defendant Appearing Pro Se No appearances by other Parties WICKS, Magistrate Judge: While this case has had its fair share of discovery disputes and countless motion practice, the Court is now confronted with an issue that attorneys should never want to be a part of: the use of generative artificial intelligence (“AI”) to assist in the drafting of legal papers that results in the creation of a legal submission containing citations to fictitious or non-existent legal authority – commonly referred to as “hallucinated” or fake case citations. In a brief filed in opposition to Plaintiffs’ Motion to Vacate the Preliminary Injunction (ECF No. 353), pro se Defendant Harry R. Thomasson, Esq. (“Thomasson”) relied upon AI-generated content that created fictitious legal citations. Tha...
Authorities cited in the passage: United States v. Cohen, 724 F · Cartagena v. Dixon, No. 25-CV- 03552 (JLR · Kaur v. Desso, No. 25-CV-726 (AMN · Fed. R. Civ. P. 11
compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub
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