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HomeCases1S REO Opportunity 1, LLC v. 223 Howard LLC
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Corpus matter record

1S REO Opportunity 1, LLC v. 223 Howard LLC

E.D. New York · Feb 3, 2026 · Pamela K. Chen

NY / federalEditorial impact: lowfake citationscontracttrialNone Adjudicated
Direct answer

What happened in this matter?

The court identified that the plaintiff's counsel cited a non-existent case and mischaracterized the holding of a real case in their summary judgment briefing. While the court noted these errors, it did not impose sanctions, instead granting the plaintiff's motion for summary judgment based on the merits of the foreclosure claim.

Why the court cared
Fabricated: Case Law | Plaintiff cited Gustavia Home, LLC v. Rice, 2020 WL 4917915 (E.D.N.Y. Aug. 21, 2020), a Westlaw citation that does not exist; the number corresponds to Durrett v. IKO Indus., Inc. (Ky. Ct. App.), and the actual Gustavia Rice decision cited by court is 2016 WL 6683473 which states the opposite proposition.
Why it matters now
A Westlaw pincite that resolves to a different case is a red flag; shepardize every cite before filing.

Why this matter is tracked

In a mortgage foreclosure action, the plaintiff submitted a memorandum of law containing a fabricated legal citation. The plaintiff cited 'Gustavia Home, LLC v. Rice, 2020 WL 4917915 (E.D.N.Y. Aug. 21, 2020),' a case that does not exist in the cited jurisdiction. The Westlaw citation provided actually corresponds to a Kentucky Court of Appeals decision, Durrett v. IKO Indus., Inc. Furthermore, the plaintiff intended to cite a real case, Gustavia Home, LLC v. Rice, 2016 WL 6683473 (E.D.N.Y. Nov. 14, 2016), but the plaintiff's brief relied on that case for the exact opposite legal proposition than what the court held. The presiding judge noted these errors in the Memorandum & Order while granting the plaintiff's motion for summary judgment on other grounds.

Operational lesson

A Westlaw pincite that resolves to a different case is a red flag; shepardize every cite before filing.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtE.D. New York
Recorded decision-makerPamela K. Chen · United States District Judge
Jurisdictionfederal
Circuit2nd Circuit
DateFeb 3, 2026
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeThe court granted the plaintiff's motion for summary judgment, finding the plaintiff established its prima facie case for foreclosure despite the errors in the plaintiff's legal briefing.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

reported

AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.

Procedural posture

The court granted the plaintiff's motion for summary judgment in a mortgage foreclosure action, while noting the plaintiff's use of a fabricated citation and mischaracterized authority in its briefing.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

1 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Plaintiff cited Gustavia Home, LLC v. Rice, 2020 WL 4917915 (E.D.N.Y. Aug. 21, 2020), a Westlaw citation that does not exist; the number corresponds to Durrett v. IKO Indus., Inc. (Ky. Ct. App.), and the actual Gustavia Rice decision cited by court is 2016 WL 6683473 which states the opposite proposition.

Questions this record answers

What happened in 1S REO Opportunity 1, LLC v. 223 Howard LLC?
The court identified that the plaintiff's counsel cited a non-existent case and mischaracterized the holding of a real case in their summary judgment briefing. While the court noted these errors, it did not impose sanctions, instead granting the plaintiff's motion for summary judgment based on the merits of the foreclosure claim.
Why does 1S REO Opportunity 1, LLC v. 223 Howard LLC matter for legal AI risk?
A Westlaw pincite that resolves to a different case is a red flag; shepardize every cite before filing.
What does the public record establish about 1S REO Opportunity 1, LLC v. 223 Howard LLC?
Retained unchanged after audit: the existing summary is source-specific, non-placeholder, and supported by the recorded source link. Read the underlying source before relying on it for legal advice or a filing.
Which source supports this 1S REO Opportunity 1, LLC v. 223 Howard LLC summary?
The recorded source is Damien Charlotin case archive. It is classified as publisher document archive; review the linked material and subsequent docket history before relying on this summary.

Related matters

Related by court, jurisdiction, tool, or classified failure pattern. Similarity does not imply the same facts or outcome.

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