AI-related case
Park v. Kim
AI UseCounsel admitted using ChatGPT to find supporting case law after failing to locate precedent manually. She cited a fictitious case (Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014)) in the reply brief, never verifying its existence.Hallucination DetailsOnly one hallucinated case was cited in the reply brief: Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep’t 2014). When asked to produce the case, Counsel admitted it did not exist, blaming reliance on ChatGPT.Ruling/SanctionThe Court referred Counsel to the Second Circuit’s Grievance Panel for further investigation and possible discipline. Lee was ordered to furnish a copy of the decision (translated if necessary) to her client and to file certification of compliance.Key Judicial ReasoningThe Court emphasized that attorneys must personally verify the existence and accuracy of all authorities cited. Rule 11 requires a reasonable inquiry, and no technological novelty excuses failing to meet that standard. The Second Circuit cited Mata v. Avianca approvingly, confirming that citing fake cases amounts to abusing the adversarial system.