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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

compiled by the SafeLegalAI editorial teammethodas of 2026-09-08v0.2.2coding CC BY 4.0JSON Hugging Face GitHub