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HomeCasesBurnett v. The City of New York
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Corpus matter record

Burnett v. The City of New York

SC New York · Dec 31, 2025

NY / stateEditorial impact: mediumfake citationstorttrialOrdered To Show Cause
Direct answer

What happened in this matter?

The court granted the defendants' motion for summary judgment and issued an order to show cause requiring plaintiff's counsel to explain why he should not be sanctioned for citing a nonexistent case in his opposition papers.

Why the court cared
Fabricated: Case Law | Plaintiff's counsel cited a nonexistent case (Backus v. City of Rochester, 148 AD3d 1697 [4th Dept 2017]); the court reported it was unable to locate the case and ordered counsel to show cause why he should not be sanctioned.
Why it matters now
One unverified cite is enough for a show-cause order — no exceptions to the cite-check rule, even for routine motions.

Why this matter is tracked

In a negligence action against the City of New York, the plaintiff's counsel cited a case, Backus v. City of Rochester, 148 AD3d 1697 (4th Dept 2017), to support the argument that a municipality is liable for the negligence of an independent contractor providing medical services. The court, presided over by Justice Paul A. Goetz, noted that it was unable to locate this case in any legal databases. Consequently, the court granted the defendants' motion for summary judgment, finding no special duty existed. Furthermore, the court ordered plaintiff's counsel to show cause at a hearing on January 22, 2026, why he should not be sanctioned for citing a nonexistent case.

Operational lesson

One unverified cite is enough for a show-cause order — no exceptions to the cite-check rule, even for routine motions.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtSC New York
Jurisdictionstate
Circuit2nd Circuit
DateDec 31, 2025
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeSummary judgment granted for defendants; counsel ordered to show cause regarding potential sanctions.
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

Summary judgment motion granted; order to show cause issued against plaintiff's counsel.

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's counsel cited a nonexistent case (Backus v. City of Rochester, 148 AD3d 1697 [4th Dept 2017]); the court reported it was unable to locate the case and ordered counsel to show cause why he should not be sanctioned.

Questions this record answers

What happened in Burnett v. The City of New York?
The court granted the defendants' motion for summary judgment and issued an order to show cause requiring plaintiff's counsel to explain why he should not be sanctioned for citing a nonexistent case in his opposition papers.
Why does Burnett v. The City of New York matter for legal AI risk?
One unverified cite is enough for a show-cause order — no exceptions to the cite-check rule, even for routine motions.
What does the public record establish about Burnett v. The City of New York?
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 Burnett v. The City of New York 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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