LiveVideo.AI Corp. v. Redstone et al.

LiveVideo.AI Corp. v. Redstone et al., S.D.N.Y., 24 Civ. 6290 (DEH), opinion and order filed June 9, 2026 (Judge Dale E. Ho). Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-156-livevideo-v-redstone.pdf`.

Attorney Alfred Camillo Constants III admitted he did not prepare, review, or file at least one of the plaintiff's motions. Nearly all of the motions in the case bore the hallmarks of AI fabrication: non-existent hallucinated cases, formatting unchanged from AI-platform output, and remnants of drafting prompts left in the text. The motions were meritless and filed to harass defendants and prolong litigation.

This was the second sanctioned episode in the same litigation: on September 30, 2025, the court adopted a report and recommendation imposing a $10,000 penalty, referring Constants to the Grievance Committee, and imposing a filing injunction against LiveVideo (LiveVideo II, 2025 WL 2778110). Despite the injunction and repeated admonitions, LiveVideo kept filing motions the court struck as filed in direct violation of its order; after a contempt show-cause order, its April 14, 2026 opposition again appeared to be drafted entirely by AI and contained hallucinated case citations (ORDER, pp. 2–3).

28 U.S.C. § 1927 and the court's inherent power. Sanctions: LiveVideo and Constants jointly ordered to pay $85,056 in defendants' attorneys' fees and costs within 21 days; Constants was again referred to the Grievance Committee of the district (ORDER, p. 10).

R5, Denied or Doubled Down. New motions were filed after the filing injunction and after repeated admonitions, and the April 14, 2026 opposition again contained hallucinated case citations; no AI-use disclosure, apology, or remediation is recorded. Cap 2 and Cap 5 triggered (Cap 5 non-binding at R5). Tier 1.

An attorney must prepare or at least review every filing bearing the attorney's name; filing unseen AI-drafted motions is both sanctionable and ineffective. Remove AI drafting artifacts and verify all citations before submitting.