Incident Tracker

Deutsche Bank Natl. Trust Co. v. LeTennier, 2026 NY Slip Op 00040 (App. Div. 3d Dept.)

sanctions

In what it called the first New York appellate decision addressing generative-AI sanctions, the Third Department fined defense counsel Joshua Douglass $7,500 and the defendant $2,500 under 22 NYCRR 130-1.1 after briefs contained 23 fabricated cases and counsel kept filing fake authorities after being alerted — a state intermediate-appellate precedent-setter.

Date of decision/order

2026-01-08

Court

New York Supreme Court, Appellate Division, Third Department

Jurisdiction

US-STATE

AI tool

generative AI (unspecified)

Conduct

Defense counsel filed appellate briefs, motions, and letters containing no fewer than 23 fabricated cases across five filings, plus numerous misrepresentations of real cases, and continued to add fake authorities after being alerted.

Consequence

USD 10,000