Courts on AI / Fabricated or misquoted citations
Superb Motors Inc. et al. v. Anthony Deo et al.
United States District Court for the Eastern District of New York · Federal district courts · NY · · 2025 WL 2256653 · No. 2:23-cv-06188-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 ordered counsel to pay $1,500 for filing unverified or fabricated authorities.
- Recorded conduct
- Counsel filed a submission with two fabricated case citations, including In re Marcus, 491 F.2d 56, 60 (2nd Cir. 1974). — 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.
Under the circumstances presented here and considering Thomasson’s response to the OSC, this Court is left with no choice but to impose sanctions under Rule 11 which is well in line with the developing case law. See e. g. , United States v. Cohen, 724 F. Supp. 3d 251, 258 (S. D. N. Y. 2024) (collecting cases) (“There is no doubt that sanctions can be imposed on at least some of these grounds for the citation to non-existent cases); Cartagena v. Dixon, No. 25-CV- 03552 (JLR), 2026 WL 673811, at *5 (S. D. N. Y. Mar. 10, 2026) (“Sanctions may be imposed for submitting false or nonexistent legal authority to the Court”); Kaur v. Desso, No. 25-CV-726 (AMN), 2025 WL 1895859, at *3 (N.
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