McMillian v. Zimmer US, Inc
S.D. New York · Dec 16, 2025
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- mcmillian-v-zimmer-us-inc-2025-12-16
- Observed outcome
- Sanctions imposed; counsel ordered to reimburse defendants for fees and costs.
- Known monetary consequence
- $9,000
Why this matter warrants attention
The court imposed sanctions on plaintiff's counsel for filing papers containing AI-generated hallucinations. The court ordered counsel to reimburse defendants for fees and costs resulting from the erroneous filings, with the specific amount to be determined by agreement or subsequent court order.
Fabricated: Other | Plaintiff's counsel filed papers containing unspecified AI-generated hallucinations and inaccuracies (ECF Nos. 100-03); counsel conceded the errors and the Court imposed sanctions.
Conceding AI errors early mitigates but does not eliminate monetary sanctions; verification is still the only defense.
Failure modes and consequences
- Fake Citations
- Tort
- Trial
- Monetary
- AI attribution
- Admitted
- Recorded tool
- Unidentified
- Known monetary consequence
- $9,000
- Procedural posture
- Order issued by the District Court following a teleconference regarding defective filings.
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 source does not identify the specific AI tool used.
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.
- Retain a matter-level record of source checks and corrections.