Chakma v. Sushi Katsuei, Inc.
S.D. New York · May 19, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- chakma-v-sushi-katsuei-inc-2026-05-19
- Observed outcome
- The court ordered defense counsel to pay class counsel's attorneys' fees for litigating the false submissions and imposed a $1,000 monetary penalty.
- Known monetary consequence
- $2,712
Why this matter warrants attention
The court sanctioned defense counsel for submitting AI-hallucinated citations and misapplied case law. The court ordered counsel to pay class counsel's attorneys' fees related to the false submissions and imposed a $1,000 monetary penalty for the misconduct, citing the failure to verify AI-generated output as subjective bad faith.
The court reasoned that presenting AI-generated hallucinations as valid case law constitutes subjective bad faith. It noted that counsel failed to check the accuracy of the AI output and did not attempt to correct the false submissions until prompted by opposing counsel's motion for sanctions.
This case reinforces the standard that counsel bears full responsibility for the accuracy of AI-generated filings. It confirms that courts in the Second Circuit view the failure to verify AI-hallucinated citations as subjective bad faith, warranting monetary sanctions.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Employment
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- LexisNexis AI
- Known monetary consequence
- $2,712
- Procedural posture
- Opinion and Order granting in large part Plaintiffs' motion for sanctions following discovery misconduct and the submission of false authority.
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
Counsel admitted to using generative AI.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to LexisNexis AI output as to any other research input.