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Corpus matter record

Matter of Zareh

SC New York · Feb 10, 2026

NY / stateEditorial impact: highfake citationsmisrepresented authoritycontracttrialProfessional
Direct answer

What happened in this matter?

The New York Supreme Court, Appellate Division, publicly censured respondent Omid Zareh for failing to supervise a drafting associate who used ChatGPT to generate a legal brief containing fabricated citations and misrepresented case law. The court imposed this reciprocal discipline based on findings from the U.S. District Court for the Northern District of Texas that the respondent filed an unreviewed, AI-generated brief in bad faith.

Why the court cared
Fabricated: Case Law | Brief contained numerous citation errors, including internally inconsistent and unverifiable citations; District Court concluded some citations were AI-generated and could not be verified. || Misrepresented: Case Law | Brief repeatedly misrepresented case law for propositions those cases did not support; District Court found ChatGPT described at least one cited case in the same erroneous manner.
Why it matters now
Reciprocal discipline follows a federal AI admonishment into state bar censure; one unreviewed ChatGPT brief becomes a permanent public record.

Why this matter is tracked

Fabricated: Case Law | Brief contained numerous citation errors, including internally inconsistent and unverifiable citations; District Court concluded some citations were AI-generated and could not be verified. Outcome: Respondent publicly censured. Respondent filed an opposition brief in federal litigation containing numerous citation errors and misstatements of law. The District Court found the brief AI-generated, noting ChatGPT described at least one cited case in the same erroneous manner, and admonished counsel; this Court imposed reciprocal discipline in the form of a public censure for failure to supervise and for filing an unreviewed AI-drafted brief.

Operational lesson

Reciprocal discipline follows a federal AI admonishment into state bar censure; one unreviewed ChatGPT brief becomes a permanent public record.

Record details

New YorkSingle-state evidence scope
Explore NYOpen its source-linked jurisdiction page and related matters.
CourtSC New York
Jurisdictionstate
Circuit2nd Circuit
DateFeb 10, 2026
CH
AI toolChatGPT
Party typeLawyer
OutcomeRespondent publicly censured.
Known amountNot recorded
Professional sanctionYes
Attribution boundary

What the record establishes about AI use

admitted

The District Court found the brief was generated using ChatGPT.

Procedural posture

Reciprocal disciplinary proceeding initiated by the Attorney Grievance Committee for the First Judicial Department following an admonishment by the U.S. District Court for the Northern District of Texas.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

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

  1. Fabricated: Case Law | Brief contained numerous citation errors, including internally inconsistent and unverifiable citations; District Court concluded some citations were AI-generated and could not be verified.
  2. Misrepresented: Case Law | Brief repeatedly misrepresented case law for propositions those cases did not support; District Court found ChatGPT described at least one cited case in the same erroneous manner.

Questions this record answers

What happened in Matter of Zareh?
The New York Supreme Court, Appellate Division, publicly censured respondent Omid Zareh for failing to supervise a drafting associate who used ChatGPT to generate a legal brief containing fabricated citations and misrepresented case law. The court imposed this reciprocal discipline based on findings from the U.S. District Court for the Northern District of Texas that the respondent filed an unreviewed, AI-generated brief in bad faith.
Why does Matter of Zareh matter for legal AI risk?
Reciprocal discipline follows a federal AI admonishment into state bar censure; one unreviewed ChatGPT brief becomes a permanent public record.
What does the public record establish about Matter of Zareh?
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 Matter of Zareh 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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