Evgeny Yaroshevsky v. Karlin et al.
E.D. New York · Mar 31, 2026
What happened in this matter?
The Court recommended dismissing the plaintiff's complaint with prejudice and awarding costs and attorneys' fees to the defendants as a sanction for the plaintiff's persistent use of AI-generated, fabricated legal authorities and his failure to verify citations despite repeated judicial warnings.
- Why the court cared
- The Court reasoned that the plaintiff's persistent use of nonexistent authority and failure to correct filings after multiple warnings and a safe harbor period constituted a violation of Rule 11. The Court emphasized that the plaintiff's use of generative AI without verification imposed an undue burden on the court and opposing counsel, and that the plaintiff's repeated misrepresentations to the court regarding his verification efforts demonstrated bad faith, justifying dismissal with prejudice.
- Why it matters now
- Consumer chatbots like Gemini are not research tools — ban them from the legal research workflow outright.
Why this matter is tracked
In a landlord-tenant dispute, the pro se plaintiff repeatedly submitted filings containing fabricated case law and misquoted authorities. Despite multiple warnings from the Court regarding Rule 11 obligations, the plaintiff persisted in relying on nonexistent citations, which he admitted were generated using Google Gemini without verification. The plaintiff further made material misrepresentations to the Court regarding his verification efforts. Magistrate Judge Eichenholtz issued a Report and Recommendation (R&R) finding that the plaintiff's conduct violated Rule 11 and warranted severe sanctions. The R&R recommends denying the plaintiff's belated request to amend the complaint and granting the defendants' motion for sanctions, including the dismissal of the complaint with prejudice and an award of costs and attorneys' fees.
Consumer chatbots like Gemini are not research tools — ban them from the legal research workflow outright.
Record details
What the record establishes about AI use
Plaintiff admitted using Google Gemini to obtain citations.
Report and Recommendation on Defendants' motions to dismiss and for Rule 11 sanctions.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
3 citation, quotation, or authority issues are recorded in the source dataset.
- Misrepresented: Other | Plaintiff admitted using Google Gemini to obtain citations and failed to verify them before filing, contributing to the submission of fabricated and inaccurate authorities.
- Fabricated: Case Law | Multiple authorities cited by plaintiff did not exist; defendants identified at least five nonexistent cases in the complaint and five in other filings and the Court confirmed some citations were fabricated.
- False Quotes: Case Law | Numerous quotations attributed to cases could not be found in the opinions (Defendants identified ~13 instances; the Court found at least two such misquotes earlier).
Questions this record answers
- What happened in Evgeny Yaroshevsky v. Karlin et al.?
- The Court recommended dismissing the plaintiff's complaint with prejudice and awarding costs and attorneys' fees to the defendants as a sanction for the plaintiff's persistent use of AI-generated, fabricated legal authorities and his failure to verify citations despite repeated judicial warnings.
- Why does Evgeny Yaroshevsky v. Karlin et al. matter for legal AI risk?
- Consumer chatbots like Gemini are not research tools — ban them from the legal research workflow outright.
- What does the public record establish about Evgeny Yaroshevsky v. Karlin et al.?
- 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.
- Which source supports this Evgeny Yaroshevsky v. Karlin et al. 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.