{"meta":{"exportedAt":"2026-10-16T08:49:57.965Z","formatVersion":2,"selection":{"q":"default-judgment","system":"","harm":"","context":"","country":"","role":"","relation":"core","evidence":"","year":"2026","response":"","severity":"","verification":"","view":"incidents","sort":"added"},"totalIncidents":1,"coverage":{"cases":1,"countries":1,"languages":1,"unknownLocation":0,"locationPending":0,"unknownLanguage":0,"unknownDate":0,"lawsuits":0,"regulatory":0,"minors":0,"coreRelations":1,"contextualRelations":1,"mixedRelations":1,"unknownRelations":0,"relationPending":0,"relationUnknown":0},"countingNote":"Distinct public cases in this selection. People counts apply within individual cases only; cross-case person overlap has not been resolved. No population incidence estimate.","affectedCountNote":"Interpret person counts with affectedCountStatus and the reported effects. Unquantified zeros are placeholders, not a measured zero.","source":"AI incidents","publisher":"NOPE","url":"https://nope.net/incidents","license":"CC BY 4.0"},"incidents":[{"id":"2026-new-york-federal-court-defaults-client-and-orders-lawyer-to-pay-fees-over-ai-generated-false-citations","caseFacts":{"claims":[{"id":"c1","status":"documented","evidence":[{"locator":"'motion to dismiss that was peppered with false citations'; 'Top alerted the Court to a series of faulty citations'; 'Defendants Top Experience Company LLC (“Top”) and'; 'cited that did not exist, and eight cases that did exist but did not contain the quotes'; 'Once again, his brief contained false citations'","relation":"supports","source_id":"s2"}],"assertion":"In June 2025 the defendant's lawyer filed a brief supporting its motion to dismiss that, a co-defendant's lawyer showed, cited at least thirteen cases that did not exist and eight real cases that did not contain the quoted words; a later response to the court and a proposed reply brief also contained false citations.","causal_attribution":"The court's findings in its sanctions opinion."},{"id":"c2","status":"documented","evidence":[{"locator":"'unreported cases located via Google Scholar, Google search, or the AI-assisted platform vLex, and then cite-checking those cases by running the brief through a different AI program'; 'introduced citation errors that he mistook as corrections and thus neither reviewed nor fixed'; 'I used generative AI to confirm that the information that I wrote was correctly referencing the information that I had'; 'The tool he claimed to use was NotebookLM'; 'The Court does not find the second explanation credible'; 'Court finds that explanation extremely difficult to believe'","relation":"supports","source_id":"s2"}],"assertion":"The lawyer said he located unreported cases through Google Scholar, Google search and the AI-assisted platform vLex, cite-checked the brief by running it through AI programs (vLex or Paxton AI) that he said introduced the errors, and used NotebookLM to review the content of his response; the court did not find his account of how the errors arose credible and found his NotebookLM account extremely difficult to believe.","causal_attribution":"Documented as the lawyer's statements recorded by the court; his account of how the errors arose is his own and the court rejected it in part."},{"id":"c3","status":"documented","evidence":[{"locator":"'by submitting false citations to the Court produced by generative artificial intelligence (“AI”) and then lying about their genesis'; 'had acted in bad faith'","relation":"supports","source_id":"s1"}],"assertion":"The court later described the sanctioned conduct as submitting false citations produced by generative AI and then lying about their origin, and recalled its finding that the lawyer acted in bad faith.","causal_attribution":"The court's own characterisation in the 9 October 2026 order."},{"id":"c4","status":"documented","evidence":[{"locator":"'by striking Affable’s submissions and entering default judgment against it'; 'nor a client from its attorney’s misdeeds'; 'to enter judgment in favor of Plaintiffs and against Affable Avenue LLC'; 'Dated: February 5, 2026'","relation":"supports","source_id":"s2"},{"locator":"'Court imposed terminal sanctions on Affable'","relation":"supports","source_id":"s1"}],"assertion":"On 5 February 2026 the court sanctioned the lawyer by striking his client's motion papers and entering default judgment against the client, holding that a client is not excused from its lawyer's misdeeds.","causal_attribution":"The court's order; the court ties the sanction to the false citations."},{"id":"c5","status":"documented","evidence":[{"locator":"'then-counsel to Defendant Top Experience Company LLC (“Top”), who had provided substantial assistance to the Court by investigating and reporting'; 'awards his firm $38,877.59'; 'for a total award of $38,877.59'; 'must be made by'; 'within 30 days of this Opinion, unless'; 'Dated: October 9, 2026'","relation":"supports","source_id":"s1"}],"assertion":"On 9 October 2026 the court awarded the firm of a co-defendant's former lawyer, who had investigated and reported the false citations, $38,877.59 in fees and costs, payable by the sanctioned lawyer within 30 days.","causal_attribution":"The court's order."}],"effects":[{"label":"client's motion papers struck and default judgment entered against it as a sanction on its lawyer","claim_id":"c4","direction":"negative"},{"label":"lawyer ordered to pay $38,877.59 in fees and costs","claim_id":"c5","direction":"negative"}],"sources":[{"id":"s1","url":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.364.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-16 from CourtListener RECAP storage (HTTP 200, text extracted with pdftotext); no translation was needed. ECF 364, 18 pp.","independence_group":"sdny-24-civ-9429-court-orders"},{"id":"s2","url":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.227.0.pdf","kind":"court_record","access":"read","language":"en","translation_note":"Read in full in English by the research agent (an AI) on 2026-10-16 from CourtListener RECAP storage (HTTP 200, text extracted with pdftotext); no translation was needed. ECF 227, 33 pp.","independence_group":"sdny-24-civ-9429-court-orders"}],"version":1,"ai_roles":["own_use"],"contexts":["justice","work"],"unknowns":["Which tool generated each false citation; the lawyer's account names several tools and the court rejected parts of it.","Whether the lawyer has paid the award, appealed, or been referred to a disciplinary body; neither order mentions a referral.","The amount of damages to be assessed against the defaulted client."],"geography":{"basis":"The filings were made in, and the sanctions imposed by, the U.S. District Court for the Southern District of New York. Where the lawyer and the client are based is not used.","court_countries":["US"],"event_countries":["US"],"affected_person_countries":[]},"publication":{"basis":"Published because the court's two orders, read in full, record the lawyer's own account of using AI tools to find and check citations, describe the false citations as produced by generative AI, and impose default judgment on his client and a $38,877.59 fee award on him because of them.","reviewed_on":"2026-10-16"},"ai_involvement":{"basis":"The lawyer told the court he found cases through the AI-assisted platform vLex and cite-checked his brief by running it through AI programs (vLex or Paxton AI), which he said introduced the errors, and that he used NotebookLM to review a later submission (communicated_with). The court's 9 October 2026 order describes the sanctioned filings as false citations produced by generative AI. The court read those citations and, because of them, struck the client's papers, entered default judgment against the client and ordered the lawyer to pay fees (informed_decision_about). Which tool generated each false citation is not established.","status":"supported"},"person_relations":["communicated_with","informed_decision_about"]},"name":"New York federal court enters default judgment against a defendant and orders its lawyer to pay $38,877 after false citations it found AI produced","summary":"In a federal trademark suit in the U.S. District Court for the Southern District of New York, the court on 5 February 2026 struck a company defendant's motion papers and entered default judgment against it as a sanction on its lawyer, after his filings repeatedly cited nonexistent cases and misattributed quotations. The lawyer said he had found and cite-checked cases with AI tools (vLex and Paxton AI) and used NotebookLM to review a later submission; the court rejected his explanations and found he acted in bad faith. On 9 October 2026 the court described the citations as produced by generative AI and ordered the lawyer to pay $38,877.59 in fees and costs to the firm of a co-defendant's former lawyer, who had reported the false citations to the court.","incidentDate":"2026-02-05","incidentEndDate":"2026-10-09","incidentKind":"bounded_series","incidentDatePrecision":"day","exposurePattern":"repeated_interactions","reportedDate":"2026-02-05","aiSystem":"AI legal research and cite-checking tools the lawyer said he used (vLex with AI functionality, Paxton AI) and NotebookLM, which he said he used to review his response to the court; the court found the citations were produced by generative AI","aiProduct":"vLex, Paxton AI and NotebookLM (reported)","severity":"medium","verificationStatus":"credible","harmCategories":[],"harmOutcomes":["legal_harm","professional_harm","financial_loss"],"harmOutcomeSummary":"According to the court's orders, the defendant's motion papers were struck and default judgment entered against it as a sanction for its lawyer's filings with false citations, which the court describes as produced by generative AI, and the lawyer was ordered to pay $38,877.59 in fees and costs.","frameworkFacets":[],"causationStatus":"established","participantUsersAffectedMin":1,"otherPeopleHarmedMin":0,"affectedCountStatus":"partial","affectedCountEvidence":"One person counted: the lawyer, who described his own use of AI tools and was ordered to pay $38,877.59. The client against which default judgment was entered is a company; the people behind it are not described and are not counted.","victimAgeRange":"adult","jurisdiction":"US-NY","platformType":"other","outcomeStatus":"ongoing","primarySourceUrl":"https://storage.courtlistener.com/recap/gov.uscourts.nysd.633195/gov.uscourts.nysd.633195.364.0.pdf","primarySourceLabel":"U.S. District Court for the Southern District of New York, Opinion and Order on fees, ECF 364, 24 Civ. 9429 (9 October 2026)","firstPublishedAt":"2026-10-16T03:05:26.378079+00:00","updatedAt":"2026-10-16T03:05:26.378079+00:00","scopeVersion":"facts-v3","tags":["united-states","new-york","legal-profession","sanction","hallucinated-citations","default-judgment","attorney-fees"]}]}