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Corpus matter record

H.F. v. State

CC New York · Feb 10, 2026

NY / stateEditorial impact: mediumfake citationsmisrepresented authoritytorttrialWarningStruck Filing
Direct answer

What happened in this matter?

The court struck the claimant's counsel's affirmation from the record due to the inclusion of fictitious case citations and misrepresented legal authorities. The court issued a formal warning that future submissions of non-existent case law would trigger economic sanctions and disciplinary referrals.

Why the court cared
Fabricated: Case Law | Four Court of Claims cases cited in the Manning Affirmation could not be located and were treated as fictitious by the court. || Misrepresented: Legal Norm | Counsel cited Court of Claims Act § 9(2) for the proposition that venue is proper where a claimant resides, but § 9(2) does not address venue or residence. || Misrepresented: Case Law | Counsel relied on Lepkowski v. State of New York, 1 N.Y.3d 201 (2003), in support of venue arguments though the authority did not support the proposition advanced.
Why it matters now
This record documents a Lawyer filing issue in CC New York, with the listed outcome: Brief Partly Struck; Warning.

Why this matter is tracked

In H.F. v. State, the New York Court of Claims addressed the submission of an affirmation by claimant's counsel, Timothy Manning, which contained four fictitious case citations and misrepresented legal authorities, including Court of Claims Act § 9(2) and Lepkowski v. State of New York. The court noted that counsel failed to respond to a request for copies of the unlocatable cases. Finding the conduct a violation of ethical obligations and a waste of judicial resources, the court struck the affirmation from the record. The court warned that future use of fictitious cases would result in economic sanctions and a referral to the attorney grievance committee. The underlying motion for change of venue was ultimately denied as moot.

Operational lesson

This record documents a Lawyer filing issue in CC New York, with the listed outcome: Brief Partly Struck; Warning.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtCC New York
Jurisdictionstate
Circuit2nd Circuit
DateFeb 10, 2026
AI
AI toolAI (implied, unspecified)
Party typeLawyer
OutcomeThe court struck the claimant's counsel's affirmation from the record and issued a warning regarding future conduct.
Known amountNot recorded
Professional sanctionNo
Attribution boundary

What the record establishes about AI use

implied

The court noted the citations were likely generated by AI tools used by counsel.

Procedural posture

The court addressed the conduct of claimant's counsel in an affirmation filed in opposition to the defendant's motion to change venue.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

3 citation, quotation, or authority issues are recorded in the source dataset.

  1. Fabricated: Case Law | Four Court of Claims cases cited in the Manning Affirmation could not be located and were treated as fictitious by the court.
  2. Misrepresented: Legal Norm | Counsel cited Court of Claims Act § 9(2) for the proposition that venue is proper where a claimant resides, but § 9(2) does not address venue or residence.
  3. Misrepresented: Case Law | Counsel relied on Lepkowski v. State of New York, 1 N.Y.3d 201 (2003), in support of venue arguments though the authority did not support the proposition advanced.

Questions this record answers

What happened in H.F. v. State?
The court struck the claimant's counsel's affirmation from the record due to the inclusion of fictitious case citations and misrepresented legal authorities. The court issued a formal warning that future submissions of non-existent case law would trigger economic sanctions and disciplinary referrals.
Why does H.F. v. State matter for legal AI risk?
This record documents a Lawyer filing issue in CC New York, with the listed outcome: Brief Partly Struck; Warning.
What does the public record establish about H.F. v. State?
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 H.F. v. State 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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