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Incident Tracker / United States (state)

Mendel S. v. Faigy S., 2026 NY Slip Op 26118 (Fam. Ct., Kings County)

·Family Court of the State of New York, Kings County·US-STATESanctions

A judge of the Family Court of the State of New York, Kings County, reviewing child-support objections on the court's own motion, found eleven of sixteen citations were AI-generated fictions and the rest miscited. The court imposed a USD 1,000 sanction for frivolous conduct but declined a grievance referral because counsel promptly accepted responsibility and completed AI-policy training.

Court
Family Court of the State of New York, Kings County
Date
2026-07-31
Who used the AI
Lawyer
AI tool
Not identified in the record
Conduct
Counsel, anonymised in the published opinion as 'Connor C., Esq.', filed objections in a child-support proceeding in which 11 of 16 cited authorities were fabricated and nearly all the remainder did not support the propositions cited. Counsel completed an AI-policy CLE course in response.
Outcome
Sanctions
Penalty
US$1,000
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-03

What was fabricated or misused

  • Eleven of sixteen citations in the Family Court Act § 439(e) Objection — fabricated; the opinion did not list the case names
  • Nearly all remaining real cases in the Objection — did not support the propositions asserted; the opinion did not list them

What the court said

“Upon review of the Objection, the Court discovered that Counsel repeatedly cited “hallucinated cases”—fictitious judicial authorities generated by artificial intelligence that do not exist or do not stand for the propositions asserted.”
Family Court of the State of New York, Kings County, [*1]
“Eleven of the sixteen citations were fabricated, and in nearly all instances, the real cases (once located by the Court) did not support the propositions for which counsel cited them.”
Family Court of the State of New York, Kings County, [*2]
“It would have taken minimal time for counsel — and it was also his responsibility as an attorney — to check the citations on Westlaw or Lexis to determine their veracity.”
Family Court of the State of New York, Kings County, [*4]
“The Court finds, given the facts of this case and the response filed by counsel as described above, that sanctions are appropriate, but the Court will not refer Mr. C to the Attorney Grievance Committee.”
Family Court of the State of New York, Kings County, [*5]

Timeline

  1. Court decided its sua sponte order to show cause.
  2. Opinion found eleven of sixteen citations fabricated.
  3. Court noted counsel’s response, citation log, CLE certificate, and letters.
  4. Court imposed a $1,000 sanction and declined grievance referral.

Why this case matters

Mendel brings the New York hallucinated-citation line into a Family Court child-support objection. Compared with Deutsche Bank v LeTennier, the proportion of fabricated citations was high, but the response was lower because counsel promptly took responsibility, supplied a citation log, completed AI-policy CLE, and did not keep adding fake authorities after notice. The record adds a high-volume court setting: the opinion ties wasted cite-checking time to support objections that already sit on top of heavy Family Court calendars.

Practice note

Before filing an objection under Family Court Act § 439(e), check every AI-assisted citation in Westlaw or Lexis and save the result. A post hoc citation log and AI-policy CLE may mitigate, but they do not cure the filed defect. Any response to an order to show cause should be affirmed under penalty of perjury when CPLR 2106 requires it.

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

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Mendel S. v. Faigy S., 2026 NY Slip Op 26118 (Fam. Ct., Kings County)”, safelegalai.com/tracker/mendel-s-v-faigy-s (accessed 2026-10-07). Data: CC BY 4.0.

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