New York / Citation decisions
Abuzaid v Almayouf
App. Div., 1st Dept
2026 NY Slip Op 06238
What happened
The First Department addressed a self-represented appellant’s reliance on an authority that did not appear to exist. In a footnote, it cautioned that self-representation did not excuse a failure to check the legal citations offered to a court.
The decision also concerned discovery sanctions under CPLR 3126. Those sanctions should not be described as a penalty for AI use or for the citation. The opinion does not mention AI. Its citation discussion is a caution about verification, separate from the discovery ruling.
Sanction or disposition
A caution concerning the citation. The discovery sanctions addressed elsewhere in the decision were unrelated to that caution.
From the opinion
“her pro se status does not excuse her failure to check the legal citations that she offers to a court”