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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 90/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Michael Cohen Matter
SDNY · Mar 20, 2024
/ stateEditorial impact: lowpro secriminaltrial
Direct answer
What happened in this matter?
Outcome: No Sanction on Cohen (Lawyer expected to verify); Underlying motion denied.
- Why the court cared
- The court highlighted the importance of verifying AI-generated content and the responsibility of licensed attorneys to ensure the accuracy of filings, even when research suggestions come from clients. The incident further underscored the unreliability of generative AI for legal research if used without verification
- Why it matters now
- When clients supply AI-generated research, attorneys remain the gatekeeper — verify every citation before filing.
Why this matter is tracked
Outcome: No Sanction on Cohen (Lawyer expected to verify); Underlying motion denied.
AI Use
Michael Cohen, former lawyer to Donald Trump but then disbarred, used Google Bard to find case law supporting his motion for early termination of supervised release. He stated he believed Bard was a "super-charged search engine" and was unaware it could generate fictitious cases.
Hallucination Details
Cohen provided three non-existent case citations generated by Bard to his attorney, David M. Schwartz (not the same Schwartz as in Mata), who included them in a court filing. There was a misunderstanding between Cohen and his attorneys regarding who was responsible for verifying the citations. The fake citations were discovered by Cohen's other counsel, Danya Perry, who disclosed the issue to the court. One fake citation involved a chronological impossibility.
Ruling/Sanction
Judge Jesse Furman identified the citations as fake and issued an order to show cause regarding sanctions against the attorney. However, Judge Furman ultimately declined to impose sanctions on Cohen himself, noting his non-lawyer status, his stated (though surprising) ignorance of generative AI risks, and the expectation that his licensed attorney should have verified the citations. The judge nonetheless described the incident as "embarrassing" for Cohen and denied his underlying motion on the merits.
Key Judicial Reasoning
The court highlighted the importance of verifying AI-generated content and the responsibility of licensed attorneys to ensure the accuracy of filings, even when research suggestions come from clients. The incident further underscored the unreliability of generative AI for legal research if used without verification.
Operational lesson
When clients supply AI-generated research, attorneys remain the gatekeeper — verify every citation before filing.
Record details
CourtSDNY
Jurisdictionstate
CircuitNot recorded
DateMar 20, 2024
GO
AI toolGoogle Bard
Party typePro Se Litigant
OutcomeNo Sanction on Cohen (Lawyer expected to verify); Underlying motion denied
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
Google Bard is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
No Sanction on Cohen (Lawyer expected to verify); Underlying motion denied
Correction behavior
Correction behavior is not separately verified in the current record.
Questions this record answers
- What happened in Michael Cohen Matter?
- Outcome: No Sanction on Cohen (Lawyer expected to verify); Underlying motion denied.
- Why does Michael Cohen Matter matter for legal AI risk?
- When clients supply AI-generated research, attorneys remain the gatekeeper — verify every citation before filing.
- What does the public record establish about Michael Cohen Matter?
- The record summarizes the outcome described in the linked public source. The recorded link is hosted by a court or government source. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Michael Cohen Matter summary?
- The recorded source is United States Courts. It is classified as official court or government source; 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.