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Courts on AI / Fabricated or misquoted citations

Chakma v. Sushi Katsuei, Inc.

United States District Court for the Southern District of New York · Federal district courts · NY · · No. 1:23-cv-07804-KPF · opinion

On 2026-05-19, in Chakma v. Sushi Katsuei, Inc, the Southern District of New York imposed a $2,712 monetary sanction for the defective legal authorities. Counsel filed opposition papers using authorities used for propositions they did not support. The monetary component was $2,712.

Disposition
The court imposed a $2,712 monetary sanction for the defective legal authorities.
Recorded conduct
Counsel filed opposition papers using authorities used for propositions they did not support. — outcome: sanctions; actor: lawyer; $2,712
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.

Specifically, on July 15, 2025, Plaintiffs brought to the attention of the Court that Defendants had fabricated legal authority in at least two submissions to the Court. (See Dkt. #101 (alerting the Court to Defendants’ improper citations)). The most egregious examples appeared in Defendants’ July 8, 2025 letter regarding their interference with the class notice process. There, Defendants cited Federal Rule of Civil Procedure 23 and OConner v. Agilant Solutions, Inc., 444 F. Supp. 3d 593 (S.D.N.Y. 2020), for the proposition that text messages from K. Tun could not establish misconduct by Defendants because they were inadmissible hearsay. (Dkt. #94). But Rule 23 concerns class actions, and OConner’s relevance is therefore limited because it discusses when a court may enjoin an employer-defendant from contacting putative class members through a protective order. See 444 F. Supp. 3d at 606-07. In that same letter, Defendants again cited OConner, as well as Haider v. Lyft, Inc., No. 20 Civ. 2997 (AJN), 2021 WL 3475621 (S.D.N.Y. Aug. ... Defendants did not seek to replace their submissions until January 21, 2026, over six months after Defendants’ original filings, and only after Plaintiffs raised these same concerns in the instant sanctions motion. (See Dkt. #133 (Defendants’ request to replace the submissions); Dkt. #125 (“Pl. Br.”) at 19 (Plaintiffs’ brief noting that Defendants “have done nothing” to “remedy the false submissions”)). C. The Instant Motion Taking all of the above into account, the Court set a briefing schedule at the September 16, 2025 hearing for Plaintiffs to file a motion for sanctions. (See September 16, 2025 Minute Entry). On November 13, 2025, Plaintiffs filed their motion for sanctions and supporting papers. (Dkt. #124-126). Defendants filed their opposition and supporting papers on January 13, 2026. (Dkt. #131-132).

Authorities cited in the passage: Federal Rule of Civil Procedure 23 and OConner v. Agilant Solutions · Haider v. Lyft · Federal Rule of Civil Procedure 23 · Rule 23

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