Compiled by Citation Safe (Digital Empire Holdings LLC) from the court’s published sanction order (decided September 9, 2026). Quotes and case details come from the order itself — check the primary source before relying on them.

Sanction teardown · SC New York, USA · 2026-09-09

Youssian v Village of Kings Point

What happened

In SC New York, USA, a filing relied on Spellbook AI to help draft legal argument. The court identified the following problems with the citations in that filing:

Misrepresented (Case Law)

The petition attributed to Astacio a holding that an agency cannot accept an applicant’s assertions about environmental impacts at face value and must exercise independent judgment under SEQRA. The court found that the quotation and proposition were fabricated or altered and were not the holding of the case.
Misrepresented (Case Law)

The petition used Chem Specialties to support arguments concerning the challenged planning-board approval. The court found that the quotation and legal proposition attributed to the case were fabricated or altered.
Misrepresented (Case Law)

The petition cited Douglaston for the proposition that a lapsed subdivision approval is a legal nullity. The court stated that this was not what the Court of Appeals held and that the case was improperly used to support the merits.
Misrepresented (Case Law)

The petition repeatedly cited Pell for the proposition that a planning board’s rejection of an engineer’s conclusions without a reasoned basis automatically establishes an arbitrary and capricious determination. The court found multiple bogus quotations and explained that Pell concerned review of disproportionate administrative penalties, not planning boards or ordinances.

Which AI tool

Spellbook AI. 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

Petition and amended petition stricken; Monetary Sanction; Adverse Costs Order (monetary penalty: 15000 USD.)

Additional detail

Petitioners’ counsel used Spellbook AI in drafting an Article 78 petition and memorandum that contained fabricated quotations and materially misrepresented holdings from legitimate cases. The court specifically found that Astacio, Chem Specialties, Douglaston, and Pell were cited for propositions they did not support, with Pell having nothing to do with planning boards or ordinances. After initially denying the errors and later conceding AI citation errors, counsel was sanctioned $5,000 under New York’s frivolous-conduct rules and ordered to pay $8,000 to 22 Liam Properties LLC and $2,000 to the Village respondents for fees and costs. Because the pleadings were substantially founded on the hallucinated authorities, the court struck both the original and amended petitions and dismissed the action.

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/3110/Youssian_v_Village_of_Kings_Point_USA_9_September_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).