Gurpreet Kaur v. Captain Joel Desso
N.D. New York · Jul 9, 2025
- Jurisdiction
- federal
- Court
- N.D. New York
- Record ID
- gurpreet-kaur-v-captain-joel-desso-2025-07-09
- Observed outcome
- The court imposed a $1,000 monetary sanction, required completion of a CLE course on AI ethics, and ordered the attorney to provide proof of service of the order to his client.
- Known monetary consequence
- $1,000
Why this matter warrants attention
The court sanctioned attorney Dennis Desmarais for submitting a brief containing fabricated legal quotations generated by Claude Sonnet 4. Finding a violation of Rule 11 and subjective bad faith, the court imposed a $1,000 fine, mandated completion of an AI-focused CLE course, and required the attorney to notify his client of the sanction.
The court reasoned that there is no distinction between fabricating cases and fabricating quotations from real cases, as both mislead the court. It found subjective bad faith because the attorney was aware of AI hallucination risks yet failed to perform any verification, even after the government flagged the errors in its own brief.
Fabricated quotes from real cases are treated the same as fake cases; verify every quotation against the opinion before signing Rule 11.
Failure modes and consequences
- Fabricated Quotes
- Immigration
- Trial
- Monetary
- Professional
- AI attribution
- Admitted
- Recorded tool
- Claude Sonnet 4
- Known monetary consequence
- $1,000
- Procedural posture
- The court issued an order to show cause regarding Rule 11 sanctions following the submission of a supplemental brief containing fabricated legal authority. The court subsequently issued a final order imposing sanctions.
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
Counsel admitted using Claude Sonnet 4.
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
- Compare every quoted passage and pincite directly with the underlying opinion or filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to Claude Sonnet 4 output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.