Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided July 31, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · Family Court New York, USA · 2026-07-31

Mendel S. v. Faigy S.

What happened

In Family Court 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:

Fabricated (Case Law)

Court found 11 of 16 citations in counsel's Objection were fabricated AI-generated cases that do not exist.
Misrepresented (Case Law)

In nearly all remaining instances, the real cases that could be located did not support the propositions for which counsel cited them (misstated or misrepresented precedents).

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

Monetary Sanction (monetary penalty: 1000 USD.)

Additional detail

The Family Court sua sponte reviewed counsel's Objection and determined that 11 of 16 cited authorities were fabricated AI-generated cases and that, in nearly all other instances, real cases did not support the propositions asserted. The Court concluded counsel's failure to verify AI-produced citations amounted to frivolous conduct under 22 NYCRR § 130-1.1, wasted judicial resources, and warranted a sanction. The court imposed a $1,000 monetary sanction but declined to refer counsel to the Attorney Grievance Committee, noting counsel's timely acceptance of responsibility and remorse as mitigating factors.

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/2893/In_re_Mendels_USA_31_July_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).