New York / Citation decisions
Idehen v Stoute-Phillip
Civ. Ct., Queens County
2025 NY Slip Op 51211(U)
What happened
In a Housing Court proceeding, the landlord’s counsel submitted an affirmation citing seven nonexistent cases. At the ensuing hearing, counsel acknowledged researching with Copilot, then attributed the filing to hacking before retracting that explanation. Counsel also filed an 88-page appendix intended to explain the authorities that should have been cited.
The appendix contained real decisions, but the court found that they did not address the issues or support the propositions for which they were offered. It identified indications of AI-generated summaries and a lack of candor at the hearing. The court distinguished the initial false citations from the later conduct that implicated counsel’s honesty and fitness to practice.
Sanction or disposition
$1,000 payable to the Lawyers’ Fund for Client Protection, referral to the appropriate grievance committee, and service of the order on the clients.
From the opinion
“escalated his conduct from merely frivolous to egregious misconduct which implicates his honesty, trustworthiness, and fitness to practice law”