ApodictaShow me on my files

New York · federal district court · 2025

Park v. Parker

District Court, S.D. New York, 11 April 2025. What the court wrote about citations that did not exist, in its own words, from the document on file.

Case record · S.D.N.Y.

  1. Court. District Court, S.D. New YorkCOURT
  2. Level. federal district courtLEVEL
  3. Date. 11 April 2025DATED
  4. Docket. No. 1:25-cv-00789DOCKET
  5. Judge. Mark A. BarnettJUDGE
  6. Documents. one document, 3 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 71, 11 April 2025 · source · PDF · 12 pages

Docket text. EXHIBIT TO PLEADING re: 48 Amended Complaint,. Document filed by Minhye Park. (Attachments: # 1 Exhibit 1.30, 2024_ judgment-Solely on AI Citation Without Reviewing Sanctions Record or Underlying Facts, # 2 Exhibit 12.30, 2024_ E-Mail_ Notice of Hearing & Investigation Report, # 3 Exhibit 3.31, 2025_ E-Mail_Hearing 4.14, 2025, # 4 Exhibit Judiciary Law 90 (10) & Local rule 46.2, # 5 Exhibit TRANSCRIPT_park v kim 8.11, 2021, # 6 Exhibit Expert Report (Plaintiff), # 7 Exhibit 9.22, 2021_ Motion for Sanctions against Hayley Newman, # 8 Exhibit 3.15, 2022_Motion for Sanctions against Hayley Newman).(Lee, Jae Soog) (Entered: 04/11/2025)

Lee. Lee’s reply brief in this case includes a citation to a non-existent case, which she Case 22-2057, Document 179, 01/30/2024, 3606904, Page2 of 12 3 admits she generated using the artificial intelligence tool ChatGPT. Because citation in a brief to a non-existent case suggests conduct that falls below the basic obligations of counsel, we refer Attorney Lee to the Court’s Grievance Panel, and further direct Attorney Lee to furnish a copy of this decision to her client, Plaintiff-Appellant Park.

172 (hereinafter, “Response”). Although Attorney Lee did not expressly indicate as much in her Response, the reason she could not provide a copy of the case is that it does not exist – and indeed, Attorney Lee refers to the case at one point as “this non- existent case.” Id. at 2. Attorney Lee’s Response states: I encountered difficulties in locating a relevant case to establish a minimum wage for an injured worker lacking prior year income records for compensation determination . . . .

Attorney Lee’s submission of a brief relying on non-existent authority reveals that she failed to determine that the argument she made was “legally tenable.” Cooter & Gell, 496 U.S. at 393.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from District Court, S.D. New York, from New York, or from 2025. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

Show me on one of my files →

This case is about a cite nobody opened. See a cite checked against the record before it renders, on your own file.

Show me on one of my filesTry the gate
Show me on my files