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 · memorandum 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
- Plaintiffs’ sanctions motion was granted in part; defendants and defense counsel were ordered to pay fees and costs, and defense counsel was fined $1,000.
- Recorded conduct
- Defense counsel used LexisNexis’s AI tool in multiple submissions and admitted some citations and a reference to “§ 3.01” resulted from AI hallucinations. The court ordered defense counsel to pay $1,710 in fees and a $1,000 court penalty. — outcome: fine; actor: lawyer; $1,000
- 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.
...ct in the amount of $46,980. Second, the Court orders Defendants to pay Class Counsel’s costs in Case 1:23-cv-07804-KPF Document 142 Filed 05/19/26 Page 2 of 37 the amount of $781.88. Third, the Court orders Defense Counsel to pay Class Counsel’s attorneys’ fees associated with Defense Counsel’s use of improper authority and generative AI in the amount of $1,710. Fourth, the Court imposes a $1,000 monetary penalty on Defense Counsel for the same. BACKGROUND A. The Court’s Decision in Sushi Katsuei I On February 7, 2025, the Court issued an Opinion and Order certifying a Class and a Subclass in this case. See Sushi Katsuei I, 2025 WL 429730, at *14. (See Dkt. #60). The Class includes “all tipped food-service employees other than sushi chefs who worked for Defendants at the Sushi Katsuei restaurants...
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