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Courts on AI / Fabricated or misquoted citations

Kleyman Law Group, P.C. v. James Kaloidis

Supreme Court of the State of New York · State trial courts · NY · · No. D: KINGS COUNTY CLERK 04/14/2026 11: 19 A · order

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 held the plaintiff’s papers sanctionable as frivolous because they were riddled with fictitious cases and authorities that did not support the propositions asserted.
Recorded conduct
The filing used fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Winston & Strawn LLP and Matter of Witham v Witham, which the court found nonexistent, misquoted, or unsupported. — 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.

st Dept 2007]) ( on page 10). The memorandum again cites the fictitious case Matter of Winston & Strawn LLP (on page 11) and cites the fictitious case Edgeworth Food Corp. v Stephenson (53 NY2d 962 [1981]). 12 The memorandum again misrepresents the holdings in Fontanetta and David (on page 11 ), again cites the fictitious case Credit Agricole Indosuez (twice on page 12) and again misrepresents the holding in VisionChina Media Inc. (twice on page 12). The memorandum again misrepresents the holdings in JSC VTB Bank and Societe Generate Alsacienne De Banque (on page 13) and cites the fictitious case of Tash v Perlmutter ( 453 NYS2d 61 [2 nd Dept 1982]) (on page 13). The memorandum cites the fictitious case of Matter of Witham v Witham (122 AD3d 781 [2d Dept 2014]) (on page 13), again cites the fictitious case of Edgeworth Food Corp. and again misrepresents the holding in JSC VTB Bank (both on page 13 ). The memorandum again cites the fictitious case of Credit Agricole There is a case entitled Ma v Lien (198 AD2d 186 [1 st Department 19931). There is a case entitled

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)

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