United States · Legal Practice

US Attorney Fictitious Citation Case

Attorneys submitted court filings containing fictitious judicial decisions and citations fabricated by generative artificial intelligence, and continued to provide inaccurate materials after being challenged. The court imposed sanctions accordingly.

Court or tribunal
United States District Court for the Southern District of New York
Decision date
21 June 2023
Procedural status
Sanctions order
Case number
22-cv-1461 (PKC)

01

Factual background & dispute

  • Attorneys used a chat-based tool for legal research and drafting.
  • The court filings cited non-existent judicial decisions accompanied by fabricated judicial opinions.
  • When directed by the court to verify the citations, the filers failed to conduct reliable verification.

02

Core issues & judicial focus

  1. An attorney's duty of verification when using generative artificial intelligence
  2. The professional responsibilities and procedural consequences of submitting false materials to a court

03

Judicial finding & holding

  • The court imposed sanctions on the responsible attorneys and law firm, ordering them to notify affected judges and parties.
  • The order emphasized that practitioners remain responsible for all submitted filings.

04

Practical risk implications

01Verify statutes, precedents, citations, and factual assertions individually against authoritative primary sources.

02Law firms should implement review protocols, citation checks, and filing approval logs for AI-generated content.

Court documentsFull judgments and orders1 document

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