Case D-168 · AI Sanctions Case Tracker

Lawand Hill v. Foundation Media LLC

U.S. District Court for the Southern District of New York, No. 1:25-cv-5947-AS, October 2026 (NO SANCTION; first no-sanction declination with a training-policy warning)

Response class R3, Half-Owned It

The case

Copyright infringement case overseen by U.S. District Judge Arun Subramanian (S.D.N.Y., Manhattan); order issued the first week of October 2026 (reported October 2, 2026). Attorney: Cynthia Arato of Shapiro Arato Bach, representing defendant Foundation Media. Reporting: https://www.reuters.com/legal/litigation/judge-warns-ai-could-stunt-lawyers-training-harm-their-clients-2026-10-02/, the caption, established from the court's filings in the full pass, is Lawand Hill v. Foundation Media LLC, No. 1:25-cv-5947-AS. In a prior order the previous month, the judge had questioned whether "unchecked" use of AI led to citation errors in a defense filing.

What happened

Arato apologized and said the citation errors stemmed from another lawyer at her firm who prepared the initial draft and finalized it before filing. In a declaration she said the unnamed lawyer acted "contrary to the firm's policies and training," and that the failure to check AI-generated citations was "an isolated error and not any bad faith or intent to mislead or deceive the court." She said the firm was implementing further safeguards. In a separate filing submitted the same week, Arato disclosed that the firm had used AI tools created by legal-technology company Harvey to help prepare the improperly vetted filing.

The rule and the sanction

NO SANCTION IMPOSED, the judge declined to sanction the lawyers, accepting the apology and the no-bad-faith representation. Instead he used the order to warn the profession: the episode should be a "wakeup call," with AI-generated legal work checked carefully for accuracy. He warned that AI use could stunt junior lawyers' training and harm clients, "While clients may demand the use of AI to save money, there is a risk of adverse consequences when things go wrong. For this reason, it might make sense to clients to think hard before requiring counsel to use AI for tasks such as the drafting of briefs", and suggested firms "think about ways to ensure that junior lawyers are getting the training they need, even as reliance on these technological tools increases," including requiring initial brief drafts to be prepared without AI assistance: "The use of AI may be unavoidable, but mentoring young lawyers is a joint responsibility that we all share."

How the lawyer responded

R3, Half-Owned It (court-triggered inquiry; AI use and failure admitted and apology given in the first declaration; remediation described only as "taken steps" and "implementing further safeguards"; responsibility for the unchecked citations attributed to the drafting lawyer; no sanction imposed, no candor credit stated in the order).

How it could have been avoided

The court declined to sanction, accepting the apology and the no-bad-faith representation; the order states no candor credit, and the response grade (R3, see (6)) rests on the response record: candor and apology in the first declaration, but remediation described only as steps taken and safeguards being implemented, responsibility placed on the drafting lawyer, and tool identity disclosed in two stages. But the signer still faced the judge while the drafter stayed unnamed; delegating the draft never delegates the signature. And a legal-specific AI tool (Harvey) gets no more leniency than a general one: retrieve every cited authority through a separate verified source and check each quotation against the opinion text. Separately, this entry is the first in which a judge prescribed law-firm training policy, expect future orders to treat the firm's junior-lawyer supervision as part of the compliance picture, not background.

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