Hall v. The Academy Charter School

Hall v. The Academy Charter School, United States District Court for the Eastern District of New York, August 7, 2025, No. 2:24-cv-08630-JMW, Doc. 32. Magistrate Judge James M. Wicks. Copy of primary document: ~/workspace/goals/ai-sanctions-case-monitoring/files/sources/D-78-hall-v-academy-charter-school.pdf

Plaintiff's counsel filed an opposition brief containing fictitious legal citations. The court found counsel "relied upon AI-generated content that created fictitious legal citations," in violation of Rule 11. Counsel responded that a law clerk drafted the opposition using Google for research and that she reviewed the draft but did not check the citations. The court treated the matter as generative-AI misuse despite counsel's denial.

The court declined to impose monetary sanctions, finding no subjective bad faith and crediting counsel's remorse, but it publicly admonished counsel in a published order and directed her to serve the plaintiff with a copy of the memorandum and order. Caveat: counsel denied using AI (attributing the errors to a clerk's Google research); the AI finding is the court's inference. Tier 2 client-notice requirement with a public admonishment.

Check every citation in a filing regardless of who drafted it; supervisory review cannot be skipped. Keep a record of the research tools used so the source of errors can be identified and addressed.