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.

HomeCasesBenjamin v. Costco Wholesale Corp

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Corpus matter record

Benjamin v. Costco Wholesale Corp

E.D. New York · Apr 24, 2025

NY / federal Editorial impact: high bar referral trial Monetary Bar Referral

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

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CourtE.D. New York

Jurisdictionfederal

Circuit2nd Circuit

DateApr 24, 2025

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.

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Linked evidence record

caselaw.findlaw.com

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Public-record statuspublic record, not an allegation-only entry

Indexing eligibilitypublicly indexable with evidence status disclosed

Evidence-review statussource unavailable

Published and maintained byManu Ayala · AI VortexIndependent legal AI risk intelligence

Evidence review recorded Jul 27, 2026

Source host classified Attribution boundary stated Limitations disclosed

Corpus checked Sep 10, 2026; latest tracked decision Sep 8, 2026. AI Vortex summarizes public records and does not replace the court document or legal research service.

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Evidence boundary

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.

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