Incident Tracker / United States (state)
Ellen Michaelis v. Wilmington Savings Fund Society
·Supreme Court of the State of New York·US-STATEOtherprovisional
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
- Date
- 2026-04-03
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- The motion used false quotations, fabricated or nonexistent authorities and mischaracterized authorities, including Matter of Sakow and Kruger v. Kruger, 107 AD3d 1285, 1287, which the court found nonexistent, misquoted, or unsupported.
- Outcome
- Other
- 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, “Ellen Michaelis v. Wilmington Savings Fund Society”, safelegalai.com/tracker/ellen-michaelis-v-wilmington-savings-fund-society (accessed 2026-09-08). Data: CC BY 4.0.