Grymes Development Company v. Fodera
The case
Grymes Development Company v. Fodera, Index No. 102723/2009 (N.Y. Sup. Ct., Richmond County), decision and order filed November 10, 2025, reported at 88 Misc. 3d 767, 245 N.Y.S.3d 863, 2025 N.Y. Slip Op. 25245. State trial court. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-106-grymes-v-fodera.pdf`.
What happened
Attorney Sungchan Cho used AI in preparing a summary-judgment motion and relied on a nonexistent case (identified in the decision as the "Landry" case), filing the motion without confirming the authority existed.
The rule and the sanction
The court denied the summary-judgment motion with prejudice and imposed monetary sanctions totaling $18,993.50: $2,000 to the Lawyers Fund for Client Protection, $11,718.50 in reimbursement to Stewart Title, and $5,275 to First Nationwide.
How it could have been avoided
(a) Read the full text of every case cited in a dispositive motion; a summary-judgment motion built on a fake case is doomed twice over. (b) Run AI-assisted research through a traditional citator before filing. (c) Remember that courts will look past a single bad citation: once one fabrication is found, the whole motion loses credibility.
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