Courts on AI / Fabricated or misquoted citations

Keefe v. BMakin Film Ltd

Supreme Court of the State of New York, Kings County · State trial courts · NY · 2026-04-24 · 2026 WL 1164759; 2026 N.Y. Slip Op. 31794(U) · No. No. 525621/2025 · order

Fabricated or misquoted citations

The New York Supreme Court on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Keefe v. BMakin Film Ltd. The self-represented party filed a motion with one fabricated case citation, two false case quotations, and one mischaracterized case citation, including Klapper v. Graziano.

Disposition: Makinen’s motion to vacate was denied; the court refused to consider motion papers based on fictitious authority and warned that further AI-generated filings with fictitious quotes and citations would bring monetary sanctions.
Recorded conduct: Makinen filed pro se motion papers and a memorandum containing AI-generated arguments, incorrect citations, many phantom cases, and phantom quotes; the court specifically identified incorrect Clark and Shah citations and a Klapper quote that did not appear in the case. — 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.

BMakin Film Ltd, 2026 WL 1164759 (2026) sanctions or both shall be entered as a judgment of the court. In no event shall the amount of sanctions imposed exceed $10,000 for any single occurrence of frivolous conduct. ” *3 Submissions that rely on non-existent cases generated by artificial intelligence, resulting in AI “hallucinations” and cases that do not stand for the propositions alleged, are considered “frivolous conduct” under 22 NYCRR § 130-1. 1 and are sanctionable. See Will of Samuel, 82 Misc 3d 616, 621 (Sur Ct 2024). A party's pro se status does not excuse such conduct. **5 It is clear and undisputed that Makinen used Artificial Intelligence to create the documents relied upon in his motions.

Authorities cited in the passage: Cited 'Klapper v. Graziano, 41 Misc 3d 401, 410 (Sup Ct 2013)' and attributed the statement that releases 'a · Cited 'Clark v. Velsiplast Corp., 88 A.D.2d 859 (1st Dep't 1982)' and quoted from it, but the citation is incorrec · Cited 'Shah v. Levy, 56 A.D.3d 574 (2d Dep't 2008)' for a proposition unrelated to that action

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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