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Courts on AI / Fabricated or misquoted citations

Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al.

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

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
The court fined counsel $2,500 and ordered counsel to notify the client about the AI-related citation errors.
Recorded conduct
Counsel filed a brief with seven fabricated case citations after using LexisNexis. — 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.

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