Flycatcher v. Affable Avenue (1)
S.D. New York · Jul 18, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- flycatcher-v-affable-avenue-1-2025-07-18
- Observed outcome
- The court denied the request to file an amended brief and reserved its decision on whether to impose sanctions or strike the original filing from the docket.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court identified that counsel submitted a brief containing a fabricated quote attributed to Mata v. Avianca, which was actually sourced from a third-party article. The court rejected counsel's reliance on AI hallucination as an excuse for failing to verify citations, denied a request to amend the filing, and reserved its decision on sanctions pending a scheduled hearing.
The court reasoned that counsel's errors were not inadvertent but resulted from deliberate choices to rely on unverified AI-generated content, violating the professional obligation under Rule 11 to ensure the accuracy of legal submissions.
Never quote Mata v. Avianca from memory; verify every case-law quote against the primary source before filing.
Failure modes and consequences
- Hallucinated_case_law
- Failure_to_verify_citations
- Misattribution_of_quotes
- Fabricated Quotes
- Contract
- Trial
- AI attribution
- Implied
- Recorded tool
- Unidentified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court issued an Order to Show Cause regarding Rule 11 sanctions, reviewed counsel's response, and subsequently reserved its decision on sanctions pending an in-person conference.
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
Court references counsel's use of AI technology.
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
- Implement mandatory verification procedures for all case law citations and quotes against primary legal databases.
- Avoid relying on AI-generated drafts for legal research without independent verification of every cited authority.
- Ensure that any identified citation errors are disclosed to the court immediately upon discovery.