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NY Court Sanctions Attorney $10.5K for AI-Generated Fake Citations

Published
Score
11

Why it matters

New York's Appellate Division, Second Department, has sanctioned attorney Michael Sanders and his law firm $10,500 combined for submitting a brief laden with fabricated legal citations and false quotations generated by artificial intelligence. Sanders personally must pay $8,000, while his firm pays $2,500 to the Lawyers' Fund for Client Protection. The court found the brief contained citations to nonexistent cases and quotations that contradicted actual law, all apparently produced by a generative AI tool.

The specific cases Sanders cited and the underlying civil matter remain unclear from available court records. The opinion does not detail how opposing counsel discovered the fabrications or what procedural posture triggered the sanctions motion.

This ruling joins a growing line of judicial discipline targeting AI misuse in legal filings. A California attorney faced a $10,000 fine in 2025 for citing 21 fake ChatGPT cases, and two attorneys were sanctioned $30,000 by the Sixth Circuit in March 2026 for similar AI-generated hallucinations. The New York court's decision carries particular weight as a published warning: lawyers bear personal responsibility for verifying every citation, regardless of source. For practitioners, the message is unambiguous—generative AI tools cannot replace citation checking, and courts will impose meaningful sanctions for failures of verification.

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