AI-related case
Ramirez v. Humala
AI UseA paralegal used public search tools and unspecified “AI-based research assistants” to generate legal citations. The resulting hallucinated cases were passed to Counsel, who filed them without verification. Four out of eight cited cases were found to be fictitious:London v. Polish Slavic Fed. Credit Union, No. 19-CV-6645Rosario v. 2022 E. Tremont Hous. Dev. Fund Corp., No. 21-CV-9010Paniagua v. El Gallo No. 3 Corp., No. 22-CV-7073Luna v. Gon Way Constr., Inc., No. 20-CV-893Ruling/SanctionThe court imposed a $1,000 sanction against Counsel and her firm. Counsel was ordered to serve the sanction order on her client and file proof of service. The court declined harsher penalties, crediting her swift admission, apology, and internal reforms.Key Judicial ReasoningThe court found subjective bad faith due to the complete absence of verification. It cited a range of other AI-related sanction decisions, underscoring that even outsourcing to a “diligent and trusted” paralegal is not a defense when due diligence is absent.
Judges: Rachel Peter Kovner