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Chakma v. Sushi Katsuei, Inc.

Court
S.D. New York
Jurisdiction
USA
Decided
2026-05-19
AI tool
LexisNexis AI
Outcome
Monetary Sanction
Monetary penalty
2712 USD

What was hallucinated

Fabricated: Doctrinal Work | Defense Counsel cited a non-sourced authority "§ 3.01 Certification Is Crucial Step In Class Actions," which the Court found resulted from AI hallucination and lacked any identifiable source. || Misrepresented: Case Law | Defense Counsel repeatedly relied on OConner and Haider to argue that third-party communications could not be attributed to defendants; the Court found these cases irrelevant to the agency/attribution issue and thus misapplied.

Sanction teardown · S.D. New York, USA · 2026-05-19

Chakma v. Sushi Katsuei, Inc.

What happened

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

  • Fabricated (Doctrinal Work)
    Defense Counsel cited a non-sourced authority "§ 3.01 Certification Is Crucial Step In Class Actions," which the Court found resulted from AI hallucination and lacked any identifiable source.
  • Misrepresented (Case Law)
    Defense Counsel repeatedly relied on OConner and Haider to argue that third-party communications could not be attributed to defendants; the Court found these cases irrelevant to the agency/attribution issue and thus misapplied.

Which AI tool

LexisNexis 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

Monetary Sanction (monetary penalty: 2712 USD.)

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/2160/Chakma_et_al_v_Sushi_Katsuei_Inc_et_al_USA_19_May_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/2160/Chakma_et_al_v_Sushi_Katsuei_Inc_et_al_USA_19_May_2026.pdf

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