· App. Div., 2d Dept
Sibrizzi v Strickland
2026 NY Slip Op 06477
Citation misrepresentations prompted an order to show cause; the opinion does not attribute them to AI.
The decision library
New York AI-citation decisions
What the courts found, what followed, and the words of the opinions themselves.
This collection covers AI-related citation failures and decisions about citation checking where the court did not attribute the errors to AI. Each account distinguishes the conduct, the sanction and any question left open by the opinion. Dates below are decision dates.
Read the New York rules and policy alongside the decisions.
· App. Div., 1st Dept
Abuzaid v Almayouf
2026 NY Slip Op 06238
A citation that did not appear to exist drew a caution to a self-represented appellant, separate from discovery sanctions.
· App. Div., 2d Dept
Landberg v City of New York
2026 NY Slip Op 03935
A GenAI-assisted appeal contained fictitious cases, invented quotations and misstatements of real decisions; counsel and the firm were sanctioned.
· App. Div., 2d Dept
Matter of Julien v Arthur
2026 NY Slip Op 03308
A self-represented father’s custody appeal used a fictitious authority and unfinished placeholders; the court imposed $250.
· Sup. Ct., Dutchess County
Michaelis v Wilmington Sav. Fund Socy., FSB
2026 NY Slip Op 26048
A renewal motion contained hallucinated authorities and lacked the part’s GenAI certification; the court reached the merits without a monetary sanction.
· App. Div., 1st Dept
Matter of Zareh
2026 NY Slip Op 00619
Reciprocal discipline followed a federal finding concerning an unreviewed, AI-drafted brief.
· Sup. Ct., Suffolk County
Cassata v Michael Macrina Architect, P.C.
2026 NY Slip Op 26014
An opposition brief contained nonexistent decisions, invented quotations and unsupported propositions; papers were stricken and counsel and the firm were sanctioned.
· App. Div., 3d Dept
Deutsche Bank Natl. Trust Co. v LeTennier
2026 NY Slip Op 00040
At least 23 fabricated authorities appeared across five appellate filings, with more than half submitted after notice of the problem.
· Sup. Ct., New York County
Ader v Ader
2025 NY Slip Op 51563(U)
An opposition to a sanctions motion repeated the AI citation and quotation failures that had prompted the motion.
· Civ. Ct., Queens County
Idehen v Stoute-Phillip
2025 NY Slip Op 51211(U)
Seven nonexistent cases were followed by an 88-page appendix that failed to support the propositions offered; counsel was fined and referred.
· Surr. Ct., Kings County
Matter of Samuel
2024 NY Slip Op 24014
Probate reply papers relied on erroneous or nonexistent cases; the affirmation was stricken and a sanctions appearance ordered.