Kleyman Law Group v. Kaloidis
The case
Kleyman Law Group, P.C. v. Kaloidis, N.Y. Sup. Ct., Kings County, No. 502644/2025, sanctions order filed August 4, 2026. Copy of primary document: `~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-163-kleyman-law-group-v-kaloidis.pdf`.
What happened
The firm's attorney (Kleyman) testified at a June 9, 2026 sanctions hearing that from April 2025 to December 2025 he used "Claude" and other generative AI research platforms to prepare court submissions. Across 19 separate submissions, he cited 23 fictitious decisions and materially misrepresented the holdings, facts, or governing law of at least 83 genuine decisions. Some submissions were filed even after the opposing party flagged the fabricated citations in June 2025. He said he could not afford Lexis or Westlaw, did not understand the platforms could fabricate authorities, and conceded he could have verified them with a free internet search but did not.
The rule and the sanction
22 NYCRR section 130-1.1 (frivolous conduct). An April 13, 2026 decision had already found the filings frivolous and ordered the sanctions hearing; the August 4, 2026 order imposed a $10,000 sanction payable to the Lawyers' Fund, $36,511.35 in attorney's fees and costs, and a referral to the Attorney Grievance Committee, for a fixed monetary total of $46,511.35. Note: the instructions flag that an April 2026 order and this August 2026 order are the same matter; this entry covers both orders as a single matter.
How it could have been avoided
Inability to afford premium databases does not lower the verification duty; a free internet search would have caught the fictitious cases. When opposing counsel flags bad citations, stop and re-verify every authority rather than filing more submissions with the same defects.
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