Matter of Zareh
SC New York · Feb 10, 2026
- Jurisdiction
- state
- Court
- SC New York
- Record ID
- matter-of-zareh-2026-02-10
- Observed outcome
- Respondent publicly censured.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
Reciprocal discipline follows a federal AI admonishment into state bar censure; one unreviewed ChatGPT brief becomes a permanent public record.
Failure modes and consequences
- Fake Citations
- Misrepresented Authority
- Contract
- Trial
- Professional
- AI attribution
- Admitted
- Recorded tool
- ChatGPT
- Known monetary consequence
- Not recorded
- 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.
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 District Court found the brief was generated using ChatGPT.
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.
- Assign a responsible reviewer for AI-assisted research and drafting.
- Use only approved research and drafting tools for legal work.
- Set a written rule for permissible AI use and mandatory verification.