In the Matter of Omid Zareh
The case
In the Matter of Omid Zareh, Motion No. 2025-04518, Case No. 2025-05041 (1st Dep't), entered February 10, 2026, 2026 N.Y. Slip Op. 00619, 2026 WL 363103. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-127-in-re-zareh.pdf`. Source URL: https://www.damiencharlotin.com/documents/1816/Matter_of_Zareh.pdf
What happened
As a reviewing attorney in federal litigation in the Northern District of Texas, Zareh submitted a brief containing numerous citation errors and misrepresented case law. The district court found the brief was AI-generated (ChatGPT described at least one cited case in the same erroneous manner as counsel), found the drafting associate's denials of AI use not credible, and found that Zareh, while probably unaware of the AI use at first, failed in supervising the drafting attorney and acted in bad faith by defending the unreviewed brief.
The rule and the sanction
The district court admonished Zareh for violating FRCP 11(b). On reciprocal-discipline principles, the First Department imposed a public censure on Zareh, the New York equivalent of the federal court's public reprimand, noting that the FRCP 11 misconduct would also violate New York Rules of Professional Conduct 3.1(a), 3.1(b)(1), and (in footnote) the supervisory rules 5.1(b)(2) and 5.1(d)(2)(ii).
How it could have been avoided
(a) Reviewing attorneys must actually review the briefs they sign; supervising a drafting attorney means checking the citations, not just the argument structure. (b) Defending an unreviewed AI-drafted brief after errors surface compounds the original fault into bad faith. (c) Supervisory responsibility under the ethics rules attaches whether or not the supervisor knew AI was used.