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Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 14, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · E.D. New York, USA · 2026-09-14

Henry v. Long Island University

What happened

In E.D. New York, USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

  • Outdated Advice (Overturned Case Law)
    Counsel presented Kruchowski as a Second Circuit decision, but the cited case was from the Tenth Circuit and the opinion had been withdrawn and superseded by a 2006 revised opinion.
  • Fabricated (Case Law)
    Counsel cited Nichols v. Princeton Int’l Ins. Agency, Inc. with a 2005 WL citation for a duress proposition. The cited WL number was a Senate Agriculture Committee testimony transcript, not the asserted case; counsel substituted Nicholas v. Nynex, Inc. as a correction.
  • Fabricated (Case Law)
    Counsel cited Torrence v. Kuehne v. Nagel, Inc. as an E.D.N.Y. case, but the WL citation was a declaration filed in the Central District of California and the asserted case did not exist.
  • Fabricated (Case Law)
    The court could not confirm the cited D.C. Circuit case existed; it found only a Northern District of Florida case with the same name.
  • False Quotes (Case Law)
    Counsel attributed the statement that exhaustion is satisfied by timely filing an EEOC charge to Williams, but the quoted language does not appear in that decision.
  • Fabricated (Case Law)
    The court could not confirm that the cited Loewen decision existed.
  • False Quotes (Case Law)
    Counsel attributed a strict-compliance quotation concerning the ADEA to Butcher, but the quoted language does not appear in that decision.
  • Fabricated (Case Law)
    The court could not confirm that the cited Stewart decision existed.
  • False Quotes (Case Law)
    Counsel attributed a duress and prompt-repudiation quotation to VKK, but the quoted language does not appear in that decision.
  • Fabricated (Case Law)
    The court could not confirm that the cited Proformance decision existed; it found only a Supreme Court of New Jersey case with the same name.
  • Fabricated (Case Law)
    The court could not confirm that the cited Jiggetts decision existed.
  • Fabricated (Case Law)
    The court could not confirm the incomplete citation to Scheuer v. Trustees of CUNY.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Two-year filing-disclosure sanction

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

Check a brief before you file it → · See our live false-verify rate

Source: https://www.damiencharlotin.com/documents/3114/Henry_v._Long_Island_University_USA_14_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).