Flycatcher v. Affable Avenue
S.D. New York · Feb 5, 2026
What happened in this matter?
The Court sanctioned counsel for repeatedly filing submissions containing AI-hallucinated case citations and false quotes. Finding that counsel acted in bad faith and failed to verify authorities despite multiple warnings, the Court struck the filings and entered default judgment against the client, Affable Avenue LLC.
- Why the court cared
- Fabricated: Case Law | Affable's motion to dismiss included numerous non-existent case citations generated by AI; Opposing counsel identified at least 13 fabricated cases and the Court found 14 of 60 citations to be fake. || Fabricated: Case Law | Proposed reply brief cited a nonexistent "Himmelstein v. Comcast of the D.C., LLC, 908 F.3d 49; aff'g 44 F. Supp. 3d 1 (D.D.C. 2012)"—citations that do not exist and were inconsistent with the intended New York Court of Appeals decision. || False Quotes: Case Law | Response to Order to Show Cause quoted a passage presented as from Mata v. Avianca but the quoted language was actually from a secondary article by Christopher F. Lyon; counsel failed to attribute the quote properly. || Misrepresented: Case Law | Reply brief and subsequent explanations showed misattributed/mismatched reporter citations (e.g., counsel relied on a Google Scholar result for Himmelstein that returned unrelated D.D.C. citations like 931 F. Supp. 2d 48), reflecting AI- or search-induced misrepresentation of the authoritative source.
- Why it matters now
- Paid legal-AI tools (vLex, Paxton, NotebookLM) do not cure verification duty; bad-faith denial converts sanctions into default judgment.
Why this matter is tracked
Fabricated: Case Law | Affable's motion to dismiss included numerous non-existent case citations generated by AI; Opposing counsel identified at least 13 fabricated cases and the Court found 14 of 60 citations to be fake. Outcome: Brief Struck; Default Judgment. Counsel Steven A. Feldman repeatedly filed submissions containing AI-generated nonexistent case citations and misattributed quotations. Opposing counsel flagged numerous errors; the Court found fabricated citations and false quotes, concluded counsel acted in bad faith or with conscious avoidance, struck the filings, and entered default judgment against counsel's client Affable Avenue LLC. The Court permitted opposing counsel to apply for attorneys' fees.
Paid legal-AI tools (vLex, Paxton, NotebookLM) do not cure verification duty; bad-faith denial converts sanctions into default judgment.
Record details
What the record establishes about AI use
Counsel admitted using vLex and other internal tools.
The Court issued an Order to Show Cause regarding Rule 11 violations, held a sanctions conference, and subsequently entered default judgment against the defendant.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
4 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Affable's motion to dismiss included numerous non-existent case citations generated by AI; Opposing counsel identified at least 13 fabricated cases and the Court found 14 of 60 citations to be fake.
- Fabricated: Case Law | Proposed reply brief cited a nonexistent "Himmelstein v. Comcast of the D.C., LLC, 908 F.3d 49; aff'g 44 F. Supp. 3d 1 (D.D.C. 2012)"—citations that do not exist and were inconsistent with the intended New York Court of Appeals decision.
- False Quotes: Case Law | Response to Order to Show Cause quoted a passage presented as from Mata v. Avianca but the quoted language was actually from a secondary article by Christopher F. Lyon; counsel failed to attribute the quote properly.
- Misrepresented: Case Law | Reply brief and subsequent explanations showed misattributed/mismatched reporter citations (e.g., counsel relied on a Google Scholar result for Himmelstein that returned unrelated D.D.C. citations like 931 F. Supp. 2d 48), reflecting AI- or search-induced misrepresentation of the authoritative source.
Questions this record answers
- What happened in Flycatcher v. Affable Avenue?
- The Court sanctioned counsel for repeatedly filing submissions containing AI-hallucinated case citations and false quotes. Finding that counsel acted in bad faith and failed to verify authorities despite multiple warnings, the Court struck the filings and entered default judgment against the client, Affable Avenue LLC.
- Why does Flycatcher v. Affable Avenue matter for legal AI risk?
- Paid legal-AI tools (vLex, Paxton, NotebookLM) do not cure verification duty; bad-faith denial converts sanctions into default judgment.
- What does the public record establish about Flycatcher v. Affable Avenue?
- 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 Flycatcher v. Affable Avenue 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.