In the Matter of Janelle Melissa Lewis, an attorney and counselor-at-law
App. Div. 1st Dept (NY) · May 14, 2026
- Jurisdiction
- state
- Court
- App. Div. 1st Dept (NY)
- Record ID
- in-the-matter-of-janelle-melissa-lewis-an-attorney-and-counselor-at-law-2026-05-14
- Observed outcome
- Immediate interim suspension from the practice of law.
- Known monetary consequence
- $1,500
Why this matter warrants attention
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.
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).
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.
Failure modes and consequences
- Fake Citations
- Immigration
- Trial
- Monetary
- Bar Referral
- Professional
- AI attribution
- Explicitly Recorded
- Recorded tool
- ChatGPT or a similar artificial intelligence program
- Known monetary consequence
- $1,500
- Procedural posture
- 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.
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 attributed the hallucinations to ChatGPT or a similar artificial intelligence program.
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 AI-generated legal research and citations prior to filing.
- Establish clear internal incident response procedures for addressing potential AI-related errors in work product.
- Ensure full cooperation with disciplinary authorities if an investigation is initiated to avoid compounding professional consequences.
- Maintain documentation of research verification steps to demonstrate due diligence in the event of a challenge.