Incident Tracker / United States (state)
Keefe v. BMakin Film Ltd
·Supreme Court of the State of New York, Kings County·US-STATEFiling struckprovisional
The New York Supreme Court on 2026-04-24 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Keefe v. BMakin Film Ltd. The self-represented party filed a motion with one fabricated case citation, two false case quotations, and one mischaracterized case citation, including Klapper v. Graziano.
- Court
- Supreme Court of the State of New York, Kings County
- Date
- 2026-04-24
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Makinen filed pro se motion papers and a memorandum containing AI-generated arguments, incorrect citations, many phantom cases, and phantom quotes; the court specifically identified incorrect Clark and Shah citations and a Klapper quote that did not appear in the case.
- Outcome
- Filing struck
- 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, “Keefe v. BMakin Film Ltd”, safelegalai.com/tracker/keefe-v-bmakin-film-ltd (accessed 2026-10-07). Data: CC BY 4.0.