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Courts on AI / Fabricated or misquoted citations

M7 Indústria e Comércio de Compensados e Laminados v. U.S. Structural Plywood Integrity Coalition, et al.

United States District Court for the Southern District of New York · Federal district courts · NY · · No. Case 1:25-cv-04568-PKC · order

Southern District of New York on 2026-03-09 found counsel's brief contained two citation defects, including NYNEX Corp. v. Discon, involving nonexistent authorities, fabricated or misattributed quotations. The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.

Disposition
The court ordered counsel to show cause why sanctions, striking, or referral should not issue for the defective authorities.
Recorded conduct
Counsel's brief contained two citation defects, including NYNEX Corp. v. Discon, involving nonexistent authorities, fabricated or misattributed quotations. — outcome: pending; actor: lawyer
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.

their cause to be just.” Int’l Railways of Cent. Am. v. United Brands Co., 532 F.2d 231, 239 (2d Cir. 1976). [ECF 23 at 16] Why is there a “need” for the Order? Because if fake quotes are not dealt with appropriately, they will proliferate. Tolerating them or ignoring them is a luxury the American judicial system cannot afford. Why is it “distressing”? Because of the widespread reporting on such phenomena since the spring of 2023, one would think that serious lawyers would be on their guard against fabrications, hallucinations and bogus material. See Mata v. Avianca, Inc, 678 F. Supp. 3d 443 (S.D.N.Y. 2023). It raises in the mind of the prudent jurist questions of what else the judge ought not trust in the lawyer’s brief. The distrust it breeds has the potential to hurt clients. Within fourteen days of this Order, counsel signing the brief, Michael Stanton, shall file a declaration fully, truthfully and with complete candor explaining how this happened.

Authorities cited in the passage: Plaintiffs' memorandum attributed this quoted passage to NYNEX Corp. v. Discon · Plaintiffs' memorandum attributed this quoted passage to Int’l Railways of Cent. Am. v. United Brands Co · Int’l Railways of Cent. Am. v. United Brands Co · See Mata v. Avianca

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