Burlingame v. Argo Private Client Group, Ltd. et al.
S.D. New York · Dec 17, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- burlingame-v-argo-private-client-group-ltd-et-al-2025-12-17
- Observed outcome
- The court granted one defendant's motion to dismiss and transferred the remainder of the case to the Northern District of Ohio. The court declined to impose sanctions, leaving the decision to the transferee court.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court identified multiple fabricated case citations and misrepresented quotations in plaintiff counsel's filings. The judge explicitly attributed these errors to counsel's reliance on artificial intelligence without verification. Although the court noted it would have considered sanctions, it declined to impose them, deferring the matter to the transferee court due to the transfer of the case.
False Quotes: Case Law | Counsel included quotations attributed to In re Vivendi Universal that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || False Quotes: Case Law | Counsel included quotations attributed to In re Parmalat that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || Fabricated: Case Law | Plaintiff counsel cited 'Midlantic Nat’l Bank v. Havens, 1994 WL 760822, at *4 (S.D.N.Y. Dec. 27, 1994)' to support unjust enrichment; the court found that Midlantic does not appear to exist. || Misrepresented: Case Law | Plaintiff counsel cited In re Refco, 826 F. Supp. 2d 478, 512 (S.D.N.Y. 2011) as supporting unjust enrichment; the court found that Refco does not mention unjust enrichment and thus was misused.
Every quote must be traceable to the cited opinion; missing quotes in a brief signal unverified AI drafting.
Failure modes and consequences
- Fabricated_case_law
- Misrepresented_case_law
- Hallucinated_quotations
- Fake Citations
- Fabricated Quotes
- Misrepresented Authority
- AI attribution
- Implied
- Recorded tool
- AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Memorandum opinion and order granting a motion to dismiss as to one defendant and transferring the remaining case to the Northern District of Ohio.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
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
The court explicitly referenced counsel's reliance on artificial intelligence.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.