Idehen and Ogieva v. Stoute-Phillip

Idehen and Ogieva v. Stoute-Phillip, Civil Court of the City of New York, Queens County, July 29, 2025. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-76-idehen-v-stoute-phillip.pdf

Attorney Innocent O. Chinweze used Microsoft Copilot to assist his research. His April 21, 2025 affirmation cited seven fictitious cases; he acknowledged he used Copilot on the night of April 9, 2025 and did not realize it could generate fake cases. After the court's May 21, 2025 Decision/Order identified the April cases as fake, he filed a June 2, 2025 affirmation with a 94-page appendix of real cases that, where he discussed them, did not support the propositions he cited them for; the court found the appendix's case summaries bore indications of AI generation and called the appendix "evidence of greater misconduct than the April 21, 2025 Affirmation that cited only to fictitious cases" (ORDER, p. 9). At the June 2, 2025 hearing he testified that his computer had been hacked and the filing changed after he drafted it, detailed the claim before the lunch recess, and retracted it after; the court called the statement "incredible and unsupported" and found he "displayed a distinct lack of candor at the hearing" (ORDER, p. 9). The court found his conduct frivolous under 22 NYCRR 130-1.1.

The court sanctioned Chinweze $1,000 under 22 NYCRR 130-1.1, payable to the Lawyers Fund for Client Protection within twenty-five days with proof filed to NYSCEF; referred him to the New York Grievance Committee for the Second, Eleventh, and Thirteenth Judicial Districts; and directed him to serve the decision and order on petitioners by first-class mail within ten days with proof of service.

Confirm that every cited case exists by pulling it from a legal database before filing. Learn the failure modes of AI research tools: they can invent plausible-looking cases, so treat AI output as a lead, not a source.