Incident Tracker / United States (federal)
Benjamin v. Costco Wholesale Corp., No. 2:24-cv-7399 (LGD) (E.D.N.Y.)
·US District Court, Eastern District of New York·US-FEDFine
In the US District Court for the Eastern District of New York, Magistrate Judge Lee G. Dunst fined attorney Victoria Hovsepyan $1,000 under Rule 11 after she used the AI platform ChatOn to draft a reply on a remand motion that cited five fake cases; the court found subjective bad faith but declined any disciplinary referral.
- Court
- US District Court, Eastern District of New York
- Date
- 2025-04-24
- Who used the AI
- Lawyer
- AI tool
- ChatOn
- Conduct
- Plaintiff's counsel Victoria Hovsepyan, pressed for time after a paralegal's draft proved unusable, used the AI app ChatOn to draft a reply in support of a motion to remand and filed it as a sworn affirmation without reading the cases; five cited cases were fake. Magistrate Judge Lee G. Dunst found a Rule 11 violation and subjective bad faith.
- Outcome
- Fine
- Penalty
- US$1,000
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Verified against listed sources
- Last checked
- 2026-09-04
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Benjamin v. Costco Wholesale Corp., No. 2:24-cv-7399 (LGD) (E.D.N.Y.)”, safelegalai.com/tracker/benjamin-v-costco (accessed 2026-09-05). Data: CC BY 4.0.