Courts on AI / Fabricated or misquoted citations
Gully v Varghese
Supreme Court of New York · State trial courts · NY · · No. 900514-25 · order
On 2026-05-12, in Gully v Varghese, Supreme Court of New York struck the self-represented plaintiff's reply submission because its case citations could not be located. A self-represented litigant filed opposition papers using nonexistent or hallucinated authorities. The document links the problem to GAI.
- Disposition
- Plaintiff’s opposition papers were struck and summary judgment was denied.
- Recorded conduct
- Gully’s pro se opposition papers contained AI hallucinations and nonexistent authorities. The court struck the defective filings. — outcome: filing struck; 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.
Having considered the parties' submissions, I find that imposition of a sanction on plaintiff is appropriate here. Initially, the purportedly authoritative cases cited by plaintiff are, indeed, fabrications, and appear to be "hallucinations" created by an artificial intelligence tool. Although the case names appear to mimic those of actual parties to real rulings issued by the Appellate Division, Third Department, the cases bearing these names concern entirely different matters, and the citations themselves are fake.
Authorities cited in the passage: 22 NYCRR 130-1.1