AI-related case
Arajuo v. Wedelstadt et al
AI UseCounsel admitted using a “new legal research medium”, appears to be a generative AI system or platform capable of generating fictitious case law. Counsel did not deny using AI, but claimed the system may have been corrupted or unreliable. The amended filing removed the false authorities.Hallucination DetailsThe court did not identify the specific fake cases but confirmed that “citations to non-existent cases” were included in Defendants’ original brief. Counsel’s subsequent filing corrected the record but did not explain how the citations passed into the brief in the first place.Ruling/SanctionJudge William Griesbach denied the motion for summary judgment on the merits, but addressed the citation misconduct separately. He cited Rule 11 and Park v. Kim (91 F.4th 610, 615 (2d Cir. 2024)) to underline the duty to verify. No formal sanctions were imposed, but counsel was explicitly warned that further use of non-existent authorities would not be tolerated.Key Judicial ReasoningThe court emphasized that even if the submission of false citations was not malicious, it was still a serious breach of Rule 11 obligations. Legal contentions must be “warranted by existing law,” and attor…
Judges: William C. Griesbach