In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law
App. Div. 1st Dept (NY) · May 14, 2026
What happened in this matter?
The court imposed an immediate interim suspension from the practice of law due to the respondent's failure to cooperate with a disciplinary investigation, including non-compliance with a judicial subpoena and failure to appear for an examination under oath, following an underlying incident involving the submission of AI-hallucinated case citations.
- Why the court cared
- The court reasoned that the respondent's failure to appear for a subpoenaed examination under oath and failure to comply with lawful investigative demands regarding professional misconduct allegations warranted an immediate interim suspension under 22 NYCRR 1240.9(a)(1) and (3).
- Why it matters now
- This case illustrates that while AI-generated hallucinations may trigger an initial grievance, the subsequent failure to cooperate with disciplinary authorities can lead to immediate, severe professional sanctions, including interim suspension, regardless of the underlying merits of the initial complaint.
Why this matter is tracked
The New York Appellate Division, First Department, suspended attorney Janelle Melissa Lewis from the practice of law, effective immediately. The disciplinary proceedings arose after the respondent was hired to draft a response to an order to show cause in a federal district court. The respondent's draft contained numerous citations to non-existent cases, which the court attributed to hallucinations produced by ChatGPT or similar AI. Following the incident, the respondent failed to cooperate with the Attorney Grievance Committee's investigation, including refusing to appear for a subpoenaed examination under oath and failing to produce requested documents. The court granted the Committee's motion for an interim suspension based on the respondent's failure to comply with lawful investigative demands and judicial subpoenas.
This case illustrates that while AI-generated hallucinations may trigger an initial grievance, the subsequent failure to cooperate with disciplinary authorities can lead to immediate, severe professional sanctions, including interim suspension, regardless of the underlying merits of the initial complaint.
Record details
What the record establishes about AI use
The court attributed the hallucinations to ChatGPT or a similar artificial intelligence program.
Interim suspension granted by the Appellate Division, First Department, pursuant to 22 NYCRR 1240.9(a)(1) and (3) following the respondent's failure to appear for a subpoenaed examination under oath.
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.
- Fabricated: Case Law | Respondent's draft brief contained numerous citations to non-existent cases; the U.S. District Court characterized those citations as hallucinations produced by ChatGPT or a similar AI.
Questions this record answers
- What happened in In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law?
- The court imposed an immediate interim suspension from the practice of law due to the respondent's failure to cooperate with a disciplinary investigation, including non-compliance with a judicial subpoena and failure to appear for an examination under oath, following an underlying incident involving the submission of AI-hallucinated case citations.
- Why does In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law matter for legal AI risk?
- This case illustrates that while AI-generated hallucinations may trigger an initial grievance, the subsequent failure to cooperate with disciplinary authorities can lead to immediate, severe professional sanctions, including interim suspension, regardless of the underlying merits of the initial complaint.
- What does the public record establish about In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law?
- 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.
- Which source supports this In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law 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
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