Courts on AI / Fabricated or misquoted citations

Sai Malena Jimenez-Fogarty v. Thomas Fogarty

United States District Court for the Southern District of New York · Federal district courts · NY · 2026-04-29 · No. 1:24-cv-08705-JLR-GWG · order

Fabricated or misquoted citations

The Southern District of New York on 2026-04-29 fined counsel $2,500 and ordered counsel to notify the client about the AI-related citation errors in Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al. Counsel filed a brief with seven fabricated case citations.

Disposition: Counsel was sanctioned $2,500 payable to the Clerk and ordered to serve the client, notify judges in pending cases, and certify compliance.
Recorded conduct: Attorney Lindsay filed two memoranda with numerous fabricated citations; the court described several nonexistent or mis-cited cases and found an AI program generated the fabricated citations. The court imposed a $2,500 court sanction. — outcome: fine; actor: lawyer; $2,500
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.

” 1st OSC at 2. While most attorneys provide such an explanation, which often involves an admission of reliance on artificial intelligence (“AI”) platforms, Lindsay’s brief sworn statement in response offers only airy generalities and conclusory statements. Her response contains no coherent explanation for how the two memoranda of law came to contain the fabricated citations. The most basic questions — most obviously: what was the source of the fabricated citations? — are never answered. Thus, Lindsay states merely that she “follow[s] a structured and diligent process designed to ensure accuracy, thoroughness, and compliance with all applicable legal and ethical standards. ” Aff.

Court document: damiencharlotin.com
Read: 2026-09-07 · court document read from a public copy; the court's own copy was not found online when checked (see notes)provisional
Found via: charlotin-hallucinations-db
Notes: Re-coded from the document 2026-09-08 (independent second read). Official copy not obtained 2026-09-08: not in the court's GovInfo feed for this docket (many district courts publish only some orders) (checked govinfo.gov (USCOURTS), CourtListener RECAP search).

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