LIFETIME WELL LLC v. IBSPOT.COM INC.

Docket entry 42, 26 January 2026 · source · PDF · 21 pages

Docket text. MEMORANDUM AND OPINION. SIGNED BY DISTRICT JUDGE MARK A. KEARNEY ON 1/26/26. 1/26/26 ENTERED & E-MAILED.(fdc) (Entered: 01/26/2026)

He simply signed his name. The paper he signed along with the New York attorney contained at least eight false case citation hallucinations generated by artificial intelligence. Our talented lawyers in Chamb ers caught these hallucinations and we directed counsel to show cause as to why we should not impose sanctions.

Lifetime Well opposed the Motion to dismiss on November 18, 2025.18 It did not use false citations but flagged one quotation presented by IBSpot.com which did not exist in the cited opinion.19 We granted IBSpot.com leave to confirm the sources of its citation errors or show cause as to why we should not impose sanctions for filing a Motion with readily apparent false citations or quotations.20 Attorney Anderson responded to the show cause order on December 5, 2025 and Attorney Goldin responded on December 9, 2025.

Nor can lawyers avoid sanctions by directing a 8 subordinate to file a pleading that will violate Rule 11(b).”45 We may “sanction lawyers for what they should have known, not just what they knew.”46 We may sua sponte “order an attorney . . . to show cause why conduct specifically described in the order has not violated Rule 11(b) ” and must issue an order before imposing monetary sanctions.47 The purpose of sanctions is to “deter repetition of the conduct or comparable conduct by others similarly situated” rather than penaliz e an attorney.48 “A sanction may include ‘non[-]monetary directives’ or ‘an order to pay a penalty into court,’ among other things.”49 Rule 11’s amendments “provides […]

We are guided by reasoning from our colleagues across the country addressing mis use of generative artificial intelligence without oversight. These violations persist despite repeated 9 judicial warnings and extensive public discussion of the risks associated with unverified artificial intelligence-assisted legal research.53 Courts accordingly continue to find it appropriate to impose sanctions on attorneys who violated Rule 11 by submitting filings relying on unsupported or fictitious legal authority . Monetary sanctions ranging from $1,000 to $10,000 are routinely imposed in response to such conduct.

Judge Scott issued a $2,500 sanction and ordered mandatory Continuing Legal Education where an attorney used ChatGPT to cite artificial cases in two separate motions .56 Judge Crone imposed a $2,000 sanction and ordered Continuing Legal Education for submitting a brief “without reading the cases cited, or even confirming the existence or validity of the cases included therein ” and after opposing counsel “ specifically identified the nonexistent legal authorities, ” the attorney “took no action to verify his research .” 57 Magistrate Judge Wormuth issued a $3,000 sanction and required the attorney self -report to the state bar disciplinary boards where the “citation errors [were] caused by […]

Attorney Goldin similarly admits the Motion to dismiss “included citations to some cases that were real but did not stand for the proposition asserted and contained non-existent quotes” and the “mistakes involved the use of generative artificial intelligence.” 80 He “accepts responsibility for his signature on the filing and recognizes the Court’s justifiable concern. ”81 Attorney Goldin does not appear to dispute his conduct violated Rule 11.82 Both Attorney Anderson and Attorney Goldin violated Rule 11 by signing and filing briefing containing false citations without confirming the accuracy of the legal authority presented.

We first address Attorney Goldin’s emphasis on the Motion’s asserted non -frivolous substance and partial success.88 This framing misses the point. The presence of some meritorious arguments does not excuse the inclusion of others supported by inaccurate, misleading, or fictitious citations. The Supreme Court through Rule 11 asks whether an attorney conducted a reasonable inquiry before signing and filing each legal contention presented to us.

Nor does partial success relieve this Chambers of the burden of independently verifying and scrutinizing legal authority certified as accurate by Attorneys Anderson and Goldin . We were required to identify and 16 disregard numerous fabricated citations before reaching the merits of any argument. Rule 11 exists to ensure courts may rely on the accuracy of the legal authority presented to them, not to excuse errors because some arguments ultimately succeed.

Docket entry 35, 9 December 2025 · source · PDF · 7 pages

Docket text. RESPONSE TO ORDER TO SHOW CAUSE by IBSPOT.COM INC.. (Attachments: # 1 Exhibit A: CLE Completion)(GOLDIN, JEFFREY) (Entered: 12/09/2025)

5 motion’s core legal contentions were, in material respects, warranted by existing law or non‑frivolous arguments for its application. That outcome meaningfully distinguishes this case from matters involving fabricated authorities or wholly baseless submissions. See, e.g.

See, e.g. OTG New York, 2025 WL 2671460 at * 1 (imposing $3,000 fine against attorney who “cited to nonexistent cases and fabricated legal propositions”). While the inaccurate quotations and overstatements are extremely serious and unacceptable, the underlying motion was not an abuse of the adversary process, and parts of the analysis were legally sound.

Co urts in analogous circumstances have recognized that candid admission of error and immediate corrective action are powerful mitigating factors and support proportionate outcomes focused on future compliance rather than punishment. See, OTG New York, 2025 WL 2671460 * 2 (holding that admission, contrition and prompt remediation called for sanctions “on the lower end” in a case involving hallucinated citations). Third, to say that deterrence has been achieved would be an understatement.

Fourth, proportionality and the absence of aggravating factors weigh against sanctions against Goldin. This case does not involve hallucinated or fictitious cases, repeated defiance or late or non‑compliant responses to the Court. Cf.

Oct. 22, 2025) (Robertson, U.S.M.J.) (imposing various non-monetary sanctions on local counsel who permitted filing of eleven pleadings with fabricated case citations, erroneous citations, quotations of nonexistent law and misstatements of law and then failed to appear for an order to show cause ) (emphasis added). On the contrary, the record reflects a prompt acknowledgment of the problem, a forthright explanation of the source of error, and remediation.