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Courts on AI / Fabricated or misquoted citations

Strategic Funding Source, Inc. v. STI-NY, LLC

Supreme Court of the State of New York, New York County · State trial courts · NY · · 2026 WL 1587346 · No. No. 651711/2019 · order

On 2026-05-28, in Strategic Funding Source, Inc. v. STI-NY, LLC, Supreme Court of New York awarded $2,000 in costs or fees caused by the defective legal authorities. Counsel filed a motion using authorities used for propositions they did not support.

Disposition
The court denied the motion and ordered defense counsel to reimburse plaintiff’s expenses and reasonable fees in responding to the motion, capped at $2,000.
Recorded conduct
Defense counsel admitted lack of diligence in relying on AI and submitted erroneous citations and arguments in motion practice. The court ordered reimbursement of plaintiff’s response costs not to exceed $2,000. — outcome: costs order; actor: lawyer; $2,000
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.

*1 Editor's Note: This document contains discussion of unverified citations, likely generated by AI tools used by a party or counsel. These citations are not attributable to the Court. The unverified citations have been preserved as part of the official record, but links are unavailable. Part 11M Motion Date 02/12/2026 Motion Seq. No. 002 Decision + Order on Motion Present: Hon. Lyle E. Frank, Justice. The following e-filed documents, listed by NYSCEF document number (Motion 002) 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62 were read on this motion to/for VACATE - DECISION/ ORDER/JUDGMENT/AWARD. Upon the foregoing documents, defendants' motion to vacate is denied and plaintiff's cross-motion is denied as moot. Defendants move to vacate a default judgment entered on or about August 21, 2025, notice of entry was filed August 26, 2025, based on an Order dated October 31, 2019 signed by the Honorable Alan Marin. ... It appears undisputed that the complaint does not require dismissal pursuant to CPLR § 3215(c) and that contrary to its moving papers, it is also conceded on reply that 22 NYCRR 202.48 is inapplicable. Defendants have simply failed to establish entitlement to the relief it seeks. The argument that it is somehow prejudiced now, 6 years after default judgment was awarded by an Order and Decision of this Court, by plaintiff's enforcement actions is without merit.

Authorities cited in the passage: 22 NYCRR 202.48

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