New York / Citation decisions
Sibrizzi v Strickland
App. Div., 2d Dept
2026 NY Slip Op 06477
What happened
A medical-malpractice appeal brought the plaintiff’s citations under review. The Second Department identified misrepresentations concerning authorities in the brief and its table of authorities. It affirmed the judgment dismissing the complaint against the hospital and separately raised the question of sanctions on its own motion.
The court directed the parties to submit affirmations or affidavits by November 25, 2026 addressing whether sanctions or costs should be imposed on plaintiff’s counsel under Part 130. This opinion does not mention AI and does not decide the sanctions amount. It belongs here as a decision about the duty to check citations, without attributing a cause the court did not find.
Sanction or disposition
An order to show cause concerning sanctions or costs. This decision imposed no monetary sanction and records no later outcome.
From the opinion
“A court may impose financial sanctions upon an attorney pursuant to 22 NYCRR 130-1.1(a) for misrepresentations concerning citations in their briefs”