Mendel S. v. Faigy S.
The case
Mendel S. v. Faigy S., N.Y. Fam. Ct., Kings County, File No. 186725, 2026 N.Y. Slip Op. 26118, 2026 WL 2264143, decided July 31, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-161-mendel-s-v-faigy-s.pdf`.
What happened
Counsel (anonymized in the opinion as "Mr. C") filed an objection containing 16 citations, of which 11 were fabricated, the product of generative AI. The opinion reviews the growing pattern of attorneys submitting AI-hallucinated authority without understanding how the tools work, with insufficient training, or with reckless disregard for their dangers.
The rule and the sanction
22 NYCRR section 130-1.1 (frivolous conduct). The court imposed a $1,000 monetary sanction payable to the Lawyers' Fund for Client Protection. The court declined to refer the matter to the Attorney Grievance Committee.
How it could have been avoided
Verify each citation in the actual reporters before filing, especially in high-volume motion practice. Eleven fabricated citations out of 16 means the checking step was skipped entirely, not merely done poorly.
---