Michael Cohen Matter
SDNY · Mar 20, 2024
- Jurisdiction
- state
- Court
- SDNY
- Record ID
- michael-cohen-matter-2024-03-20
- Observed outcome
- The motion for early termination of supervised release was denied, and the court declined to impose sanctions on the defendant or his counsel.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court denied the motion for early termination of supervised release and declined to impose sanctions on either the defendant or his counsel, finding that the submission of non-existent AI-generated citations was negligent but lacked the subjective bad faith required for sanctions.
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
When clients supply AI-generated research, attorneys remain the gatekeeper — verify every citation before filing.
Failure modes and consequences
- Pro Se
- Criminal
- Trial
- None Adjudicated
- AI attribution
- Admitted
- Recorded tool
- Google Bard
- Known monetary consequence
- Not recorded
- Procedural posture
- Opinion and Order resolving a motion for early termination of supervised release and an associated order to show cause regarding sanctions for the submission of non-existent case citations.
United States Courts
Official court or government source. The recorded link is hosted by a court or government domain.
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 defendant obtained cases and summaries from Google Bard.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Implement mandatory verification protocols for all case law citations, regardless of the research source.
- Establish clear communication protocols between clients and counsel regarding the origin and vetting of research materials.
- Train legal staff on the risks of generative AI, specifically its tendency to hallucinate fictitious legal authorities.