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Advani v. Appellate Term

Court
S.D. New York
Jurisdiction
USA
Decided
2025-08-01
AI tool
Implied
Outcome
Warning
Monetary penalty
None reported

What was hallucinated

Fabricated: Case Law | Nonexistent case cited in Plaintiff's Opposition: 'Doe v. Jindal, No. 11-388, 2011 WL 3664490, at *3 (E.D. La. Aug. 19, 2011)' (Pl.'s Opp'n 12); the Court found it does not exist. || Fabricated: Case Law | Nonexistent case cited in Plaintiff's Opposition: 'Matter of Medical Transport v NY State Dept of Health, 294 A.D.2d 574 (2d Dept 2002)' (Pl.'s Opp'n 28); the Court found it does not exist. || Fabricated: Case Law | Nonexistent case cited in Plaintiff's Sur-Reply: 'Parker v. Blauvelt Volunteer Fire Co., 93 F.3d 65, 69 (2d Cir. 1996)' (Pl.'s Sur-Reply 4); the Court found it does not exist. || Fabricated: Case Law | Nonexistent case cited in Plaintiff's Sur-Reply: 'Guggenheimer v. Ginzburg, 43 F.3d 807, 812 (3d Cir. 1994)' (Pl.'s Sur-Reply 4); the Court found it does not exist. || False Quotes: Case Law | Quotation in Plaintiff's Opposition at page 9 does not appear in the case cited, per the Court. || False Quotes: Case Law | Quotation in Plaintiff's Opposition at page 12 does not appear in the case cited, per the Court. || False Quotes: Case Law | Quotation in Plaintiff's Opposition at page 28 does not appear in the case cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 14 of her Opposition does not support the proposition for which it is cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 16 of her Opposition does not support the proposition for which it is cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 17 of her Opposition does not support the proposition for which it is cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 18 of her Opposition does not support the proposition for which it is cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 23 of her Opposition does not support the proposition for which it is cited, per the Court. || Misrepresented: Case Law | Plaintiff's citation at page 28 of her Opposition does not support the proposition for which it is cited, per the Court.

Details

"Were Advani a lawyer, the Court would consider imposing sanctions on her. But in view of the fact that she is not a lawyer and of the dismissal of this case, the Court declines to pursue the matter further and merely warns Advani that presentation of false citations, quotations, and holdings in the future may indeed result in the imposition of sanctions."

Sanction teardown · S.D. New York, USA · 2025-08-01

Advani v. Appellate Term

What happened

In S.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:

  • Fabricated (Case Law)
    Nonexistent case cited in Plaintiff's Opposition: 'Doe v. Jindal, No. 11-388, 2011 WL 3664490, at *3 (E.D. La. Aug. 19, 2011)' (Pl.'s Opp'n 12); the Court found it does not exist.
  • Fabricated (Case Law)
    Nonexistent case cited in Plaintiff's Opposition: 'Matter of Medical Transport v NY State Dept of Health, 294 A.D.2d 574 (2d Dept 2002)' (Pl.'s Opp'n 28); the Court found it does not exist.
  • Fabricated (Case Law)
    Nonexistent case cited in Plaintiff's Sur-Reply: 'Parker v. Blauvelt Volunteer Fire Co., 93 F.3d 65, 69 (2d Cir. 1996)' (Pl.'s Sur-Reply 4); the Court found it does not exist.
  • Fabricated (Case Law)
    Nonexistent case cited in Plaintiff's Sur-Reply: 'Guggenheimer v. Ginzburg, 43 F.3d 807, 812 (3d Cir. 1994)' (Pl.'s Sur-Reply 4); the Court found it does not exist.
  • False Quotes (Case Law)
    Quotation in Plaintiff's Opposition at page 9 does not appear in the case cited, per the Court.
  • False Quotes (Case Law)
    Quotation in Plaintiff's Opposition at page 12 does not appear in the case cited, per the Court.
  • False Quotes (Case Law)
    Quotation in Plaintiff's Opposition at page 28 does not appear in the case cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 14 of her Opposition does not support the proposition for which it is cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 16 of her Opposition does not support the proposition for which it is cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 17 of her Opposition does not support the proposition for which it is cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 18 of her Opposition does not support the proposition for which it is cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 23 of her Opposition does not support the proposition for which it is cited, per the Court.
  • Misrepresented (Case Law)
    Plaintiff's citation at page 28 of her Opposition does not support the proposition for which it is cited, per the Court.

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

Warning

Additional detail

"Were Advani a lawyer, the Court would consider imposing sanctions on her. But in view of the fact that she is not a lawyer and of the dismissal of this case, the Court declines to pursue the matter further and merely warns Advani that presentation of false citations, quotations, and holdings in the future may indeed result in the imposition of sanctions."

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/694/Advani_v_Appellate_Term_2nd_Judicial_Department.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/694/Advani_v_Appellate_Term_2nd_Judicial_Department.pdf

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