Benjamin v. Costco Wholesale Corp
E.D. New York · Apr 24, 2025
- Jurisdiction
- federal
- Court
- E.D. New York
- Record ID
- benjamin-v-costco-wholesale-corp-2025-04-24
- Observed outcome
- Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation
- Known monetary consequence
- $1,000
Why this matter warrants attention
Outcome: Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation.
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
Consumer AI tools under time pressure produce five fake cases; ban non-approved tools and require verification logs for sworn filings.
Failure modes and consequences
- Bar Referral
- Trial
- Monetary
- AI attribution
- Reported
- Recorded tool
- ChatOn
- Known monetary consequence
- $1,000
- Procedural posture
- Monetary sanction; public reprimand; order to serve client with decision; no disciplinary referral due to candor and remediation
caselaw.findlaw.com
Secondary or other linked source. The recorded link is not classified as an official court source or docket mirror.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
ChatOn is recorded in the source dataset; confirm the basis in the linked document.
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.
Latest evidence review: Source Unavailable (medium confidence).
Controls suggested by the public record
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to ChatOn output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.