New York / Citation decisions
Matter of Zareh
App. Div., 1st Dept
2026 NY Slip Op 00619
What happened
The First Department considered reciprocal discipline arising from a federal court’s public reprimand. The underlying brief contained errors and misrepresentations, and the federal court found that it had been drafted with AI without adequate review.
The New York proceeding addressed professional discipline rather than a Part 130 motion. The court rejected the available reciprocal-discipline defenses and determined that public censure was commensurate with the federal reprimand.
Sanction or disposition
Public censure in a reciprocal-discipline proceeding.
From the opinion
“counsel’s denial of the use of AI while admitting to not having reviewed the cited cases, and thus being unable to competently explain their appearance in the brief, constituted bad faith”