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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Benjamin v. Costco Wholesale Corp
E.D. New York · Apr 24, 2025
NY / federalEditorial impact: highbar referraltrial
Direct answer
What happened in this matter?
Outcome: Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation.
- Why the court cared
- Quoting Park v. Kim and Mata v. Avianca, the court held that submitting legal claims based on nonexistent authorities without checking them constitutes subjective bad faith. Signing a sworn filing without knowledge of its truth is independently sanctionable. Time pressure is not a defense. Lawyers cannot outsource core duties to generative AI and disclaim responsibility for the results
- Why it matters now
- Consumer AI tools under time pressure produce five fake cases; ban non-approved tools and require verification logs for sworn filings.
Why this matter is tracked
Outcome: Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation.
AI Use
Counsel used ChatOn to rewrite a reply brief with case law, under time pressure, without verifying the outputs. The five cases did not exist; citations were entirely fictional. Counsel later admitted this in a sworn declaration and at hearing, describing her actions as a lapse caused by workload and inexperience with AI.
Hallucination Details
Fabricated cases included:Klein v. E.I. Du Pont de Nemours & Co., 406 F.2d 1004 (cited case does not exist)Gordon v. N.Y. Cent. R.R. Co., 202 F. Supp. 2d 290Mitchell v. JCG Industries, 2010 WL 11627832Hollander v. Sweeney, 2005 WL 19904045Davis v. S. Farm Bureau Cas. Ins. Co., 2019 WL 3452601None of these cases matched any legal source. Counsel filed them as part of a sworn statement under penalty of perjury.
Ruling/Sanction
The court imposed a $1,000 sanction payable to the Clerk; ordered the counsel to serve the order on her client and file proof of service. The court acknowledged her sincere remorse and remedial CLE activity, but emphasized the seriousness of submitting hallucinated cases under oath. Sanctions were tailored for deterrence, not punishment.
Key Judicial Reasoning
Quoting Park v. Kim and Mata v. Avianca, the court held that submitting legal claims based on nonexistent authorities without checking them constitutes subjective bad faith. Signing a sworn filing without knowledge of its truth is independently sanctionable. Time pressure is not a defense. Lawyers cannot outsource core duties to generative AI and disclaim responsibility for the results.
Operational lesson
Consumer AI tools under time pressure produce five fake cases; ban non-approved tools and require verification logs for sworn filings.
Record details
New YorkSingle-state evidence scope
CourtE.D. New York
Jurisdictionfederal
Circuit2nd Circuit
DateApr 24, 2025
CH
AI toolChatOn
Party typeLawyer
OutcomeMonetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation
Known amount$1,000
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
ChatOn is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation
Correction behavior
Correction behavior is not separately verified in the current record.
Questions this record answers
- What happened in Benjamin v. Costco Wholesale Corp?
- Outcome: Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation.
- Why does Benjamin v. Costco Wholesale Corp matter for legal AI risk?
- Consumer AI tools under time pressure produce five fake cases; ban non-approved tools and require verification logs for sworn filings.
- What does the public record establish about Benjamin v. Costco Wholesale Corp?
- The record summarizes the outcome described in the linked public source. The recorded link is a secondary or other public source and should be checked against the docket where available. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Benjamin v. Costco Wholesale Corp summary?
- The recorded source is caselaw.findlaw.com. It is classified as secondary or other linked source; 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.