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HomeCasesGrymes Development Company v. Fodera
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Corpus matter record

Grymes Development Company v. Fodera

SC New York · Nov 10, 2025

NY / stateEditorial impact: highfake citationsfabricated quotescontracttrialMonetary
Direct answer

What happened in this matter?

The court sanctioned counsel for filing a summary judgment motion containing fabricated case law generated by AI. The court ordered a $2,000 fine to the Lawyers Fund for Client Protection and mandated reimbursement of $16,993.50 in attorney fees and costs to opposing counsel.

Why the court cared
The court determined the conduct was frivolous because the motion relied on non-existent case law, which was completely without merit in law and wasted resources. The court noted that a simple search on a legitimate legal research platform would have revealed the citation's inaccuracy. The court considered the attorney's immediate admission and apology as mitigating factors in determining the sanction amount, but emphasized that blind reliance on AI does not exempt attorneys from their professional duties of competence and independent judgment.
Why it matters now
This record documents a Lawyer filing issue in SC New York, with the listed outcome: Monetary Sanction (2,000 USD); Adverse Costs Order.

Why this matter is tracked

In a third-party action, counsel for the Third Party Plaintiffs filed a summary judgment motion relying on a non-existent case and fabricated quotations generated by an AI tool. Upon discovery of the hallucinated authority, counsel sought to withdraw the motion. The court found the filing of a motion predicated on non-existent case law to be frivolous conduct under 22 NYCRR 130-1.1, as it wasted judicial and party resources and lacked legal merit. While the court denied the motion for summary judgment with prejudice, it declined to dismiss the underlying action. The court imposed a $2,000 sanction payable to the Lawyers Fund for Client Protection and ordered counsel to reimburse opposing parties for attorney fees and costs totaling $16,993.50.

Operational lesson

This record documents a Lawyer filing issue in SC New York, with the listed outcome: Monetary Sanction (2,000 USD); Adverse Costs Order.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtSC New York
Jurisdictionstate
Circuit2nd Circuit
DateNov 10, 2025
UN
AI toolUnidentified
Party typeLawyer
OutcomeSummary judgment motion denied with prejudice; counsel sanctioned $2,000 to the Lawyers Fund for Client Protection; counsel ordered to pay $11,718.50 and $5,275.00 in attorney fees and costs to opposing parties.
Known amount$18,993
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

admitted

Opinion refers to counsel's reliance on 'artificial intelligence' without naming a specific tool.

Procedural posture

Following a summary judgment motion containing AI-generated fabricated citations, the court held a hearing on sanctions and issued a written decision denying the motion with prejudice and awarding monetary sanctions and fees.

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 | Summary judgment memorandum cited and quoted a non-existent case produced by AI; court found the authority fabricated and the reliance frivolous.

Questions this record answers

What happened in Grymes Development Company v. Fodera?
The court sanctioned counsel for filing a summary judgment motion containing fabricated case law generated by AI. The court ordered a $2,000 fine to the Lawyers Fund for Client Protection and mandated reimbursement of $16,993.50 in attorney fees and costs to opposing counsel.
Why does Grymes Development Company v. Fodera matter for legal AI risk?
This record documents a Lawyer filing issue in SC New York, with the listed outcome: Monetary Sanction (2,000 USD); Adverse Costs Order.
What does the public record establish about Grymes Development Company v. Fodera?
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 Grymes Development Company v. Fodera 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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