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Tameer Peak v. Onika Tanya Maraj-Petty, et al.

Court
S.D. New York
Jurisdiction
USA
Decided
2025-11-26
AI tool
Implied
Outcome
Plaintiff cautioned to disclose and verify any AI use
Monetary penalty
None reported

What was hallucinated

False Quotes: Case Law | Plaintiff attributed the quotation "[a] default is willful where the conduct of counsel or the litigant was egregious and was not satisfactorily explained" to Action S.A. v. Marc Rich & Co.; the court found that quotation does not appear in that opinion. || False Quotes: Case Law | Plaintiff cited S.E.C. v. McNulty for the proposition that "waiting to retain counsel does not constitute good cause," but the court found no such quote in McNulty and noted the case addresses a different procedural posture. || Misrepresented: Case Law | Plaintiff claimed Shady Records held that reputational harm is a form of prejudice; the court found Shady Records said nothing of reputational harm and was about different relief. || Fabricated: Case Law | The court observed that multiple case quotations in plaintiff's Nov. 12, 2025 opposition cannot be found in the cited cases and described them as likely AI 'hallucinated' citations.

Sanction teardown · S.D. New York, USA · 2025-11-26

Tameer Peak v. Onika Tanya Maraj-Petty, et al.

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:

  • False Quotes (Case Law)
    Plaintiff attributed the quotation "[a] default is willful where the conduct of counsel or the litigant was egregious and was not satisfactorily explained" to Action S.A. v. Marc Rich & Co.; the court found that quotation does not appear in that opinion.
  • False Quotes (Case Law)
    Plaintiff cited S.E.C. v. McNulty for the proposition that "waiting to retain counsel does not constitute good cause," but the court found no such quote in McNulty and noted the case addresses a different procedural posture.
  • Misrepresented (Case Law)
    Plaintiff claimed Shady Records held that reputational harm is a form of prejudice; the court found Shady Records said nothing of reputational harm and was about different relief.
  • Fabricated (Case Law)
    The court observed that multiple case quotations in plaintiff's Nov. 12, 2025 opposition cannot be found in the cited cases and described them as likely AI 'hallucinated' citations.

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

Plaintiff cautioned to disclose and verify any AI use

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.

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Source: https://www.damiencharlotin.com/documents/1111/Peak_v._Maraj-Pety_USA_26_November_2025.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

Source: https://www.damiencharlotin.com/documents/1111/Peak_v._Maraj-Pety_USA_26_November_2025.pdf

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