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Courts on AI / Fabricated or misquoted citations

Ellen Michaelis v. Wilmington Savings Fund Society

Supreme Court of the State of New York · State trial courts · NY · · 2026 WL 959797 · No. 2023-50982 · order

On 2026-04-03, Supreme Court of the State of New York denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287.

Disposition
The court denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing.
Recorded conduct
The motion used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287, which the court found nonexistent, misquoted, or unsupported. — outcome: other; 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.

she AD3d 1285, 1287 [3d Dept. 2013], does not exist. Rather, the provides no reasonable justification for not presenting citation is for Matter of Blocker v. Fischer, 107 AD3d 1285 this "newly discovered" evidence on her prior motions. [3d Dept. 2013], which involves an Article 78 proceeding. First, Plaintiff's only explanation for not presenting the These type hallucinations affect virtually every legal citation Selene correspondence is because she "obtained" it after that appears in Plaintiff's affirmation. dismissal. This falls short of a reasonable justification. Plaintiff previously submitted mortgage statements from This Court's Part Rules require litigants, including the Selene dated November 7, 2023 and December 7, 2023 self-represented, to submit an certification or affirmation (NYSCEF Doc. #s 72-74). Notably, the "newly discovered" that either (1) no generative artificial intelligence program correspondence, dated December 23, 2024 and January 21, was used in the drafting of any affidavit, affirmation, or 2025, was in existence well-before before Plaintiff filed her memorandum of law contained within the submission, or (2) prior motion. Given her access to the 2023 correspondence, that a generative artificial intelligence program was used but it is improbable that Plaintiff did

Authorities cited in the passage: Blocker v. Fischer, 107 AD3d 1285

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