Jimenez-Fogarty v. Fogarty

AI Hallucination Cases This database tracks legal decisions in cases where generative AI produced hallucinated content – typically fake citations, but also other types of AI-generated arguments. It does not track the (necessarily wider) universe of all fake citations or use of AI in court filings.

Subscribe Click to Download CSV Last updated: 11 June 2026 Search cases, courts, tools, tags… State Argentina (8) Australia (74) Austria (2) Belgium (4) Brazil (10) Canada (173) Chile (2) Colombia (3) Damien Charlotin 1 2 3 6/12/26, 11:53 AM AI Hallucination Cases Database – Damien Charlotin https://www.damiencharlotin.com/hallucinations/ 1/7 Cited in Jimenez Fogarty v Fogarty 24Civ8705 Decided 4/29/26 Archived on 6/12/26 This document is protected by copyright.

Czech Republic (2) Denmark (1) France (11) Germany (8) Hong Kong (2) India (11) International Arbitration (1) Ireland (6) Israel (53) Italy (7) Netherlands (6) New Zealand (7) Northern Cyprus (KKTC) (1) Papua New Guinea (1) Portugal (1) Qatar (1) Russian Federation (1) Singapore (3) South Africa (5) South Korea (4) Spain (7) Tanzania (1) The Bahamas (1) Trinidad & Tobago (1) UAE (2) Uganda (1) UK (59) USA (1116) Zimbabwe (1) Party Arbitrator (1) Expert (11) Federal Defender (1) Judge (24) Lawyer (619) Paralegal (2) Prosecutor (5) Pro Se Litigant (941) From period: Q2 2023 Nature – Category Fabricated (1336) False Quotes (427) Misrepresented (655) Outdated Advice (32) Nature – Subcategory […]

Grant et al. CA Georgia (USA) 10 June 2026 Lawyer, Judge Implied Fabricated Case Law (1) Misrepresented Case Law (1) Trial c vacate Bailey v. Sedgwick Claims Management Services, Inc.

W.D. Tennessee (USA) 8 June 2026 Lawyer Unidentified Fabricated Case Law (1) False Quotes Case Law (1) Order motion 6/12/26, 11:53 AM AI Hallucination Cases Database – Damien Charlotin https://www.damiencharlotin.com/hallucinations/ 2/7 Cited in Jimenez Fogarty v Fogarty 24Civ8705 Decided 4/29/26 Archived on 6/12/26 This document is protected by copyright. Further reproduction is prohibited without permission.

Further reproduction is prohibited without permission. Case Court / Jurisdiction Date ▼ Party Using AI AI Tool ⓘ Nature of Hallucination Outco Sanct Source: Robert Freund Withers v. City of Aberdeen N.D.

City of Aberdeen N.D. Mississippi (USA) 8 June 2026 Lawyer First Drafts Fabricated Case Law (6) False Quotes Case Law (1) Revok vice; D attorn case; M Bar R Source: Robert Freund Principal, Woodland House School & Ors. v. Shakeel Ahmad Malik HC Jammu & Kashmir and Ladakh, Srinagar (India) 6 June 2026 Judge Implied Fabricated Case Law (1) Misrepresented Case Law (1) Court impug flagge incorr citatio Source: Alvin Antony Kendall E.

Scheer v. Scheer Farms, LLC Kansas CA (USA) 5 June 2026 Pro Se Litigant Implied Fabricated Case Law (1) False Quotes Case Law (1) Adam Witkin v. Mary McGreevy SC Oregon (USA) 4 June 2026 Pro Se Litigant Unidentified Fabricated Case Law (2) Monet Brief S Djybril Voukeng Djatsa v.

AI Hallucination Cases This database tracks legal decisions in cases where generative AI produced hallucinated content – typically fake citations, but also other types of AI-generated arguments. It does not track the (necessarily wider) universe of all fake citations or use of AI in court filings.

Subscribe Click to Download CSV Last updated: 30 April 2026 Search cases, courts, tools, tags… State Argentina (8) Australia (73) Austria (2) Belgium (4) Brazil (10) Canada (147) Chile (1) Colombia (3) Damien Charlotin 1 2 3 4/30/26, 2:01 PM AI Hallucination Cases Database – Damien Charlotin https://www.damiencharlotin.com/hallucinations/ 1/6 Cited in Jimenez-Fogarty 24Civ8705 Decided 4/29/26 Archived on 4/30/26 This document is protected by copyright.

Czech Republic (2) Denmark (1) France (11) Germany (7) Hong Kong (2) India (8) International Arbitration (1) Ireland (6) Israel (51) Italy (7) Netherlands (6) New Zealand (6) Papua New Guinea (1) Qatar (1) Singapore (3) South Africa (4) South Korea (4) Spain (6) Tanzania (1) The Bahamas (1) Trinidad & Tobago (1) UAE (2) Uganda (1) UK (52) USA (931) Zimbabwe (1) Party Arbitrator (1) Expert (11) Federal Defender (1) Judge (16) Lawyer (521) Paralegal (2) Prosecutor (4) Pro Se Litigant (813) From period: Q2 2023 Nature – Category Fabricated (1140) False Quotes (359) Misrepresented (547) Outdated Advice (30) Nature – Subcategory Case Law (1216) Doctrinal Work (31) Exhibits & Submissions (98) […]

S.D. New York (USA) 29 April 2026 Lawyer LexisNexis Fabricated Case Law (7) Mo Sa to Source: Robert Freund Nisland Asset Investment, LLC v. Carissa Ann Gericke CA Iowa (USA) 29 April 2026 Pro Se Litigant Implied Fabricated Case Law (2) Misrepresented Case Law (1) Iss wa fai pro sup au 4/30/26, 2:01 PM AI Hallucination Cases Database – Damien Charlotin https://www.damiencharlotin.com/hallucinations/ 2/6 Cited in Jimenez-Fogarty 24Civ8705 Decided 4/29/26 Archived on 4/30/26 This document is protected by copyright.

Further reproduction is prohibited without permission. Case Court / Jurisdiction Date ▼ Party Using AI AI Tool ⓘ Nature of Hallucination Ou Sa Bathsheba Nichole Adams v. Kiewit Infrastructure West Company, et al.

D. Arizona (USA) 29 April 2026 Pro Se Litigant Implied Fabricated Case Law (2) Mo Wa Anthony C. Hill v.

N.D. California (USA) 28 April 2026 Lawyer CoCounsel Fabricated Case Law (1) Misrepresented Case Law (1) Ad Mo 4 h CL Cir Brandon Rulund Akins v. Tashi Latwon Ratliff, et al.

M.D. North Carolina (USA) 28 April 2026 Pro Se Litigant Implied Fabricated Case Law (9) Wa Tekoma Chaney v. Transdev Services Inc. et al.

GORENSTEIN, United States Magistrate Judge Tricia S. Lindsay, attorney for plaintiff Sai Malena Jimenez-Fogarty, responded to two motions to dismiss by filing a pair of memoranda of law that cited to numerous nonexistent cases. In response, the Court ordered Lindsay to show cause why she should not be sanctioned for her misleading filings.

The two briefs were signed by Lindsay, and each contained a number of fabricated citations.

Staropoli, 94 A.D.3d 1083, 1085 (2d Dep’t 2012). 3 for which they were cited — thus showing that the citations were completely made up. The following are descriptions of some of the fabricated citations: • Lindsay cited to “Cornhill LLC v.

P. 16(f), 28 U.S.C. § 1927, or the Court’s inherent power “for submitting memoranda of law . . . that contain numerous non-existent or improper citations.” 1st OSC at 2. To this end, the Order to Show Cause (“OSC”) required Lindsay to provide “a complete and detailed description of the process of the drafting of the two memoranda of law” and “a detailed and complete description of the role of any individual or computer system that was involved in the drafting process.” Id.

Lindsay responded to this OSC. See Resp.; Lindsay Aff.5F 6 Her explanation for how the fabricated citations ended up in her briefs is discussed in section III.A below. We note here only 6 Lindsay filed two versions of her memorandum of law and affidavit in response to the Court’s first OSC.

This statement fails to recognize that the case located at the “Case number” (presumably referring to the case whose citation is “183 A.D.3d 649”) has nothing to do with service of process. Lindsay repeats this same meaningless phrase — “Case number exists; incorrect case name” — to purportedly explain multiple fabricated citations. See id.

11, 28 U.S.C. § 1927, and the Court’s inherent power, since the submission of the fabricated citations did not violate a court order.

11(b)(2); then quoting Cooter & Gell, 466 U.S. at 393). When an attorney “rel[ies] on non-existent authority,” she “reveals” that she “made no inquiry, much less the reasonable inquiry required by Rule 11.” Id. A court is authorized to impose “an appropriate sanction on any attorney” if she violates Rule 11 “after notice and a reasonable opportunity to respond.” Fed.

152). Briefly, Plaintiff’s counsel engaged in a pattern of conduct which culminated in the filing of AI-generated, ‘hallucinated’ legal authorities in opposition papers and—when challenged—continuing apparent omission of any substantive details as to how the filing of ‘hallucinated’ authorities occurred. The Court issued an Amended Order to Show Cause requiring detailed and specific explanations from Plaintiff’s Counsel for nonexistent citations (ECF Doc.

In her belated submission, she failed to acknowledge her well- established use of AI, providing generic and generalized explanations for her erroneous citations. 2 The undersigned filed reply papers asserting that Plaintiff’s Counsel had violated Rule 11 of the Federal Rules of Civil Procedure by submitting the hallucinated case law (see ECF Doc. No.

153). It was only after that filing that Plaintiff’s Counsel conceded that she might have used “Lexis Nexis” AI systems, and that the hallucinated citations “may very well have been generated by the Lexis Nexis software during the research phase” (ECF Doc. No.

154 at page 8-9). While claiming that she “did not intentionally submit non-existent or improper citations, nor did she delegate research or drafting responsibilities to any automated system without oversight,” Counsel asserted in the same sentence that “any errors were the result of an innocent oversight in the review process, compounded by reliance on technology that, while generally reliable, is not immune to error” (ECF Doc. No.

149 at page 14). Notably absent from Plaintiff’s Counsel’s papers is any reference to either above- referenced “hallucinated” case, much less whether either discusses issues that are actually relevant to service of process. Plaintiff’s Counsel could have made this representation.

154, 159). She still does not mention either hallucinated case in her responsive papers to the Court’s last two Orders (see ECF Doc. Nos.

Perhaps one might ask why any of this motion practice matters. The use of “hallucinated” cases could easily self-generate a new state of normalcy, if courts choose complacency.1 But history dissents from that position. Justice Black, facing a case involving the fabrication of a bogus trade journal article from 1926 (well before fabrication of authorities, yet not before the invention of that fabrication, itself), has the answer: [T]ampering with the administration of justice in the manner indisputably shown here involves far more than an injury to a single litigant.

238, 246 (1944). We as jurists now face a society where truth and precedent are far easier to fabricate than they have ever been. The bedrock of our common law comes not from enacted legislation, but from the decisions—rightly or wrongly decided—that our predecessors made, pored over, reviewed, revised, and remade.

129). Specifically, those opposition papers included what appear to be ‘hallucinated’ cases. RELEVANT PROCEDURAL HISTORY The relevant procedural history in this matter is set forth at length in the accompanying Affirmation in Reply and Support, filed herewith.

RELEVANT PROCEDURAL HISTORY The relevant procedural history in this matter is set forth at length in the accompanying Affirmation in Reply and Support, filed herewith. Briefly, Plaintiff’s counsel has engaged in a pattern of similar conduct which culminated in the filing of AI-generated, ‘hallucinated’ legal authorities in opposition papers and—when challenged—apparent omission of any details regarding how the filing of ‘hallucinated’ authorities occurred. Upon retention on May 20, 2025, counsel attempted to contact Plaintiff’s counsel, requesting three weeks to respond to Plaintiff’s Second Amended Complaint.

In addition to withholding key video footage until the day when Ms. Hirshowitz’s reply papers were due, Plaintiff cited two fabricated cases in her opposition papers: “Cornhill LLC v. Sowers, 183 A.D.3d 649 (2d Dept.

Nor does either case that is reflected in the citations supplied by Plaintiff’s Counsel concern entirely different parties and legal issues unrelated to service of process. Instead, both cases appear to be AI-generated ‘hallucinated’ citations, as evidenced by the distinctive formatting patterns in Plaintiff’s papers, including embedded bullet points and redundant “Precedents Supporting Proper Service” and “Table of Evidence” sections characteristic of unsupervised drafting by Artificial Intelligence (“AI”). Rather than pointing these deficiencies out directly in the Reply papers, counsel for Ms.

Rather than pointing these deficiencies out directly in the Reply papers, counsel for Ms. Hirshowitz elected to engage the papers on their purported merits, distinguishing the ‘hallucinated’ case law as inapplicable. The Court issued an Amended Order to Show Cause requiring detailed and specific explanations from Plaintiff’s Counsel for these nonexistent citations (ECF Doc.

She did so one day late without seeking permission for further extension; failed to 3 acknowledge her use of AI despite evidence she had done so; and provided only generic explanations for her errors, failing to address how she came to cite fabricated cases that she had specifically represented as supportive of propositions related to service of process.

LEXIS 91690, 2012 WL 2564523, at *2. An emerging constellation of cases involving attorneys’ citations to AI-generated, fake, or ‘hallucinated’ authorities now charts the course for the Court’s review. Monetary sanctions for use of such ‘hallucinated’ case law range from $1,500 for minor offenses to $31,100 for more egregious ones.

17, 2025) 5 ($1,500.00 for attorney who “knowingly made accurate and misleading statements in his written reply . . . to the government’s opposition that expressly raised the fictitious case and quotation[,] and knowingly made accurate and misleading statements at the [subsequent] hearing,” but thereafter made a “post-hoc acknowledgment of the fictitious case and quotation”).