H.F. v. State
CC New York · Feb 10, 2026
- Jurisdiction
- state
- Court
- CC New York
- Record ID
- h-f-v-state-2026-02-10
- Observed outcome
- The court struck the claimant's counsel's affirmation from the record and issued a warning regarding future conduct.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
This record documents a Lawyer filing issue in CC New York, with the listed outcome: Brief Partly Struck; Warning.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Tort
- Trial
- Warning
- Struck Filing
- AI attribution
- Implied
- Recorded tool
- AI (implied, unspecified)
- Known monetary consequence
- Not recorded
- 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.
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 were likely generated by AI tools used by counsel.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify each cited authority, quotation, and proposition against the underlying source before filing.
- Confirm that every authority actually supports the proposition for which it is offered.