Incident Tracker / United States (federal)
Sana Hazina Butler v. Fidelity Management & Research Company LLC
The Southern District of New York on 2026-04-30 warned the self-represented party to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions. The self-represented party filed a pleading with one fabricated case citation, three false case quotations, and two mischaracterized case citations, including Inc. v. Neewra.
- Court
- United States District Court for the Southern District of New York
- Date
- 2026-04-30
- Who used the AI
- Litigant in person
- AI tool
- Not identified in the record
- Conduct
- Butler’s letter cited five cases with incorrect support, included three quotations not in the cited cases, and cited one nonexistent opinion, Rong Zhu v. BNP Paribas. The court believed the problems were due to generative AI and warned her.
- Outcome
- Warning
- 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, “Sana Hazina Butler v. Fidelity Management & Research Company LLC”, safelegalai.com/tracker/sana-hazina-butler-v-fidelity-management-research-company-llc-2026 (accessed 2026-10-07). Data: CC BY 4.0.