Incident Tracker / United States (federal)
In re Firestar Diamond, Inc.
The Southern District of New York denies Nirav Modi’s motion for leave to appeal a bankruptcy order. The court notes Modi used an outside person and AI tool to format the motion, identifies a false Cohen quotation and unsupported AI-generated citations, and dismisses the action.
- Court
- United States District Court for the Southern District of New York
- Date
- 2026-07-30
- Who used the AI
- Litigant in person
- AI tool
- artificial intelligence (‘AI’) tool
- Conduct
- Self-represented appellant submitted an AI-assisted bankruptcy appeal motion with a non-existent quotation and citations that did not support asserted propositions.
- Outcome
- Dismissal
- 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.
Similar incidents on the record
- Thomas v. Pangburn, No. 4:23-cv-00046-RSB-CLR (CV423-046) (S.D. Ga.)2023-10-06 · US District Court, Southern District of Georgia (Savannah Division) · DismissalIn the Southern District of Georgia, Magistrate Judge Christopher L. Ray found that pro se plaintiff Jerry Thomas cited ten nonexistent cases and never explained their origin, recommended dismissal of his amended compla…
- Ashmeade v. Amazon.com Services LLC, No. 7:23-cv-04331-KMK-VR (S.D.N.Y.)2026-08-27 · US District Court, Southern District of New York · WarningIn the Southern District of New York, self-represented plaintiff Keith Ashmeade cited two nonexistent Southern District decisions while litigating discovery issues against Amazon. Magistrate Judge Reznik identified the…
- Johnson v. Nationstar Mortgage LLC, No. 1:25-cv-00855-JRR (D. Md.)2026-08-26 · US District Court, District of Maryland · WarningIn the District of Maryland, self-represented plaintiff Darrin Johnson again cited a case the court could not locate, after an earlier Rule 11 warning. Judge Rubin said the authority appeared to be hallucinated from gen…
- Potterf v. Wessels, No. 1:26-cv-10860-MFL-PTM (E.D. Mich.)2026-08-26 · US District Court, Eastern District of Michigan · WarningIn the Eastern District of Michigan, self-represented plaintiffs admitted using artificial intelligence to draft objections with fictitious or erroneous citations and an invented Supreme Court quotation. Judge Leitman d…
Cite this record
SafeLegalAI Global Legal AI Incident Tracker, “In re Firestar Diamond, Inc.”, safelegalai.com/tracker/in-re-firestar-diamond-inc (accessed 2026-09-08). Data: CC BY 4.0.