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Courts on AI / Fabricated or misquoted citations

Sana Hazina Butler v. Fidelity Management & Research Company LLC

United States District Court for the Southern District of New York · Federal district courts · NY · · No. 1:25-cv-09337-RA-RFT · order

On 2026-05-22, in Sana Hazina Butler v. Fidelity Management & Research Company LLC, the Southern District of New York warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions. A self-represented litigant cited Rate Technology Inc. v. Speakeasy Inc even though the court found the authority did not exist.

Disposition
The court warned the filer that future use of false, nonexistent, or unsupported authorities may result in sanctions.
Recorded conduct
A self-represented litigant cited Rate Technology Inc. v. Speakeasy Inc even though the court found the authority did not exist. — outcome: warning; actor: litigant in person
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.

2024) (per curiam) (observing that the “attempt to persuade a court or oppose an adversary” by relying on “non-existent precedent” is an “abuse of the adversary system”). (ECF 43). Plaintiff’s response to Defendant’s request for a stay of discovery includes citation to a case, Rate Technology Inc. v. Speakeasy Inc., that does not match the citation provided; the case has an entirely different citation, and the case involves whether a settlement agreement barring a patent licensee from later challenging a patent’s validity was void for public policy reasons. See Rates Tech. Inc. v. Speakeasy, Inc., 685 F.3d 163, 167 (2d Cir. 2012). Plaintiff has denied using AI. Whatever the cause of Plaintiff’s false citations, she is again admonished that presentation of false citations, quotations, or holdings in the future may lead me to impose sanctions. See, e.g., Advani v. App. Term, 2nd Jud. Dep’t, No. 25- CV-1627 (JMF), 2025 WL 2201065, at *3 (S.D.N.Y. Aug. 1, 2025); Reilly v. Conn. Interlocal Risk Mgmt. Agency, No. 25-CV-640 (VDO), 2025 WL 1726366, at *3 (D. Conn.

Authorities cited in the passage: Rate Technology Inc. v. Speakeasy Inc · See Rates Tech. Inc. v. Speakeasy · Advani v. App. Term, 2nd Jud · Reilly v. Conn. Interlocal Risk Mgmt. Agency, No. 25-CV-640 (VDO)

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