Incident Tracker / United States (state)
Michaelis v. Wilmington Savings Fund Society
·Supreme Court of the State of New York, Dutchess County·US-STATENoted, no consequenceprovisional
On 2026-04-03, Supreme Court of the State of New York denied the renewed post-judgment request and enforced its generative-AI certification rule after finding hallucinated citations throughout the self-represented filing. A self-represented party submitted a motion with false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287.
- Court
- Supreme Court of the State of New York, Dutchess County
- Date
- 2026-04-03
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Plaintiff’s affirmation contained hallucinated legal cases throughout; the court identified a missing quotation from Matter of Sakow and a nonexistent Kruger v. Kruger citation.
- Outcome
- Noted, no consequence
- Penalty
- No monetary penalty recorded
- Regulatory outcome
- No separate regulatory disposition recorded
- Status
- Provisional — written by the court-decisions pipeline, awaiting the editor
- Last checked
- 2026-09-07
Primary sources for this incident
Related regulation records for this incident
No related regulation record has been linked to this incident yet.
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Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “Michaelis v. Wilmington Savings Fund Society”, safelegalai.com/tracker/ellen-michaelis-v-wilmington-savings-fund-society (accessed 2026-10-07). Data: CC BY 4.0.