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Courts on AI / Fabricated or misquoted citations

LiveVideo.AI Corp. v. Redstone

United States District Court for the Southern District of New York · Federal district courts · NY · · No. 24 Civ. 6290 · opinion

On 2026-06-09, in LiveVideo.AI Corp. v. Redstone, the Southern District of New York awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee. Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority.

Disposition
The court awarded more than $85,000 in fees and costs and referred counsel to the district grievance committee.
Recorded conduct
Counsel filed a motion using quotations that did not appear in the cited source and at least one nonexistent or hallucinated authority. — outcome: costs order; actor: lawyer; $85,056
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.

Constants also admitted that “he did not prepare, review, or file at least one of plaintiffs motions,” and nearly all of the motions in this matter contain the hallmarks of artificial intelligence (“Al”) fabrication, including non-existent hallucinated cases, formatting unchanged from that produced by Al platforms, and remnants of prompts that the drafter declined LEGAL STANDARDS’ Under § 1927, the Court may require “any attorney ... who so multiplies the proceedings in any case unreasonably and vexatiously” to pay the other party’s “excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” 28 U.S.C. § 1927. Similarly, the Court may “exercise its inherent power to sanction a party or an attorney who has acted in bad faith, vexatiously, wantonly, or for oppressive reasons.” Ransmeier v. Mariani, 718 F.3d 64, 68 (2d Cir. 2013). In practice, “the only meaningful difference between an award made under § 1927 and one made pursuant to the court’s inherent power is . . . that awards under § 1927 are made only against attorneys . . . while an award made under the court’s inherent power may be made against an attorney, a party, or both.” Enmon v. Prospect Cap.

Authorities cited in the passage: Ransmeier v. Mariani, 718 F · Enmon v. Prospect Cap

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