Gully v Varghese
SC New York · May 12, 2026
- Jurisdiction
- state
- Court
- SC New York
- Record ID
- gully-v-varghese-2026-05-12
- Observed outcome
- The court struck the plaintiff's summary judgment motion and reply memorandum due to the inclusion of fabricated case law.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court struck the plaintiff's summary judgment motion and reply memorandum because they relied on fabricated case law. The judge determined that the citations were AI-generated hallucinations and that the plaintiff's pro se status did not exempt her from the obligation to verify the accuracy of legal authorities presented to the court.
The court reasoned that filing papers with fabricated legal authorities is sanctionable as frivolous conduct under 22 NYCRR 130-1.1. The judge emphasized that pro se litigants are held to the same standards as represented parties regarding the duty to ensure the authenticity of cited authorities. The court determined that striking the offending submissions was the most appropriate consequence, finding that the plaintiff's failure to verify the citations undermined the truth-seeking function of the judicial system.
This case illustrates the judicial response to pro se litigants using AI-generated fake citations. It reinforces that courts will strike filings containing hallucinated authorities regardless of the filer's intent or representation status, emphasizing the duty of reasonable inquiry.
Failure modes and consequences
- Pro Se
- Fake Citations
- Tort
- Trial
- Struck Filing
- AI attribution
- Implied
- Recorded tool
- unspecified
- Known monetary consequence
- Not recorded
- Procedural posture
- The court addressed the plaintiff's motion for summary judgment and the defendants' cross-motion for summary judgment, alongside the plaintiff's motion to strike the defendants' bill of particulars, in a decision dated May 12, 2026.
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
The court noted the citations appear to be hallucinations created by an artificial intelligence tool.
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 protocols for all case citations, regardless of the research source.
- Establish internal review procedures for pro se filings to identify potential reliance on unverified AI-generated content.
- Train staff on the risks of AI-generated hallucinations in legal research and the necessity of cross-referencing citations against official databases.