Courts on AI / Fabricated or misquoted citations

Kleyman Law Group, P.C. v. Kaloidis

Supreme Court of the State of New York, Kings County · State trial courts · NY · 2026-04-03 · No. Index No. 502644/2025 · order

Fabricated or misquoted citations

On 2026-04-03, Supreme Court of the State of New York held the plaintiff’s papers sanctionable as frivolous because they were riddled with fictitious cases and authorities that did not support the propositions asserted. Counsel submitted a filing with fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Winston & Strawn LLP and Matter of Witham v Witham.

Disposition: The court denied most of plaintiff’s motions, dismissed only three counterclaims, vacated a TRO, granted defendant’s cross-motion for sanctions against plaintiff and Mr. Kleyman, and set a hearing on amount and possible AGC referral.
Recorded conduct: Plaintiff and Mr. Kleyman filed 19 affirmations, affidavits, memoranda, a proposed order to show cause, and a letter containing 23 fictitious cases cited 47 times and at least 83 misstatements of holdings, including filings after notice. — outcome: sanctions; 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.

Upon review of Plaintiffs submissions in Motion Sequence Nos. 1, 2, 3, 4, and 6, the court finds that those papers ... are replete with citations to nonexistent authority, as well as citations to actual cases in which the facts, applicable law, and/or holdings are materially misrepresented. Notably, Plaintiffs submissions cite 23 fictitious cases on a total of 47 occasions. ... Plaintiff seeks $50,000 in attorney's fees for work product that appears to have been generated through the use of artificial intelligence, without adequate verification of the accuracy of the cited authorities. ... Plaintiffs conduct in submitting papers riddled with fictitious citations and citations that do not stand for the propositions claimed is sanctionable as frivolous conduct pursuant to 22 NYCRR 130-1.1.

Authorities cited in the passage: Matter of Winston & Strawn LLP (on page 11) · Matter of Witham v Witham (122 AD3d 781 [2d Dept 2014]) (on page 13)

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: court site blocks automated access (checked www.nycourts.gov) Official copy not obtained 2026-09-08: court site blocks automated access (checked www.nycourts.gov) (checked www.nycourts.gov). Re-coded from the document 2026-09-08 (independent second read).

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