Which source supports this Minhye Park v. Hon. Barrington D. Parker, et al. 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.

HomeCasesMinhye Park v. Hon. Barrington D. Parker, et al.

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Corpus matter record

Minhye Park v. Hon. Barrington D. Parker, et al.

S.D. New York · Jul 15, 2026

NY / federal Editorial impact: high fake citations bar referral civil rights trial Bar Referral

Direct answer

What happened in this matter?

The Second Circuit referred attorney Jae S. Lee to its Grievance Panel and Committee for professional misconduct after Lee submitted a reply brief containing a fabricated legal citation generated by GPT-3.5. The district court later confirmed this referral was a valid judicial act protected by absolute immunity.

Why the court cared: The court reasoned that the disciplinary referral was a judicial act related to the appeal before the panel, as judges have inherent authority to manage the conduct of attorneys appearing in their court. Consequently, the judges were protected by absolute judicial immunity.
Why it matters now: This case confirms that judicial immunity protects disciplinary referrals triggered by AI-generated hallucinations. It underscores that attorneys remain strictly liable for the accuracy of their filings, regardless of whether the content was generated by an AI tool.

Why this matter is tracked

In the matter of Park v. Parker, the U.S. District Court for the Southern District of New York addressed claims arising from a prior Second Circuit disciplinary referral. The Second Circuit had previously referred attorney Jae S. Lee to its Grievance Panel and Committee after Lee included a fabricated case citation in a reply brief, which was generated by the AI tool GPT-3.5. The district court dismissed the plaintiff's subsequent action against the federal judges and other defendants, holding that the disciplinary referral was a protected judicial act within the court's jurisdiction. The court affirmed that judges possess inherent authority to manage attorney conduct and that such referrals are shielded by absolute judicial immunity.

Operational lesson

This case confirms that judicial immunity protects disciplinary referrals triggered by AI-generated hallucinations. It underscores that attorneys remain strictly liable for the accuracy of their filings, regardless of whether the content was generated by an AI tool.

Record details

New YorkSingle-state evidence scope

Explore NYOpen its source-linked jurisdiction page and related matters.

CourtS.D. New York

Jurisdictionfederal

Circuit2nd Circuit

DateJul 15, 2026

AI toolGPT-3.5

Party typeLawyer

OutcomeThe court dismissed the plaintiff's claims, upholding the validity of the Second Circuit's disciplinary referral of the attorney.

Known amountNot recorded

Professional sanctionReferral to the Second Circuit Grievance Panel and Committee.

Attribution boundary

What the record establishes about AI use

explicitly recorded

The opinion identifies GPT-3.5 as the source of the fabricated citation.

Procedural posture

The S.D. New York granted the defendants' motions to dismiss the plaintiff's Second Amended Complaint, which challenged the validity of a prior Second Circuit disciplinary referral.

Correction behavior

Correction behavior is not separately verified in the current record.

Tracked discrepancy record

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

Fabricated: Case Law | Attorney Jae S. Lee included a citation to a non-existent case generated by GPT-3.5 in a reply brief; the Second Circuit referred Lee to the Grievance Panel and Committee for that fabricated citation and the court treated the referral as a judicial act within its jurisdiction.

Questions this record answers

What happened in Minhye Park v. Hon. Barrington D. Parker, et al.?: The Second Circuit referred attorney Jae S. Lee to its Grievance Panel and Committee for professional misconduct after Lee submitted a reply brief containing a fabricated legal citation generated by GPT-3.5. The district court later confirmed this referral was a valid judicial act protected by absolute immunity.
Why does Minhye Park v. Hon. Barrington D. Parker, et al. matter for legal AI risk?: This case confirms that judicial immunity protects disciplinary referrals triggered by AI-generated hallucinations. It underscores that attorneys remain strictly liable for the accuracy of their filings, regardless of whether the content was generated by an AI tool.
What does the public record establish about Minhye Park v. Hon. Barrington D. Parker, et al.?: The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Which source supports this Minhye Park v. Hon. Barrington D. Parker, et al. 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.

Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law (2)S.D. New York · Jul 10, 2026same court · fake citations + bar referral Jason Wimberly v. Verizon New York Inc.S.D. New York · Jun 12, 2026same court · fake citations + civil rights LiveVideo.AI Corp. v. RedstoneS.D. New York · Jun 9, 2026same court · fake citations + bar referral Hodges v. McGough Enterprises LLCS.D. New York · May 26, 2026same court · fake citations + civil rights Mercy Wellington v. City of New YorkS.D. New York · Apr 30, 2026same court · fake citations + civil rights Sai Malena Jimenez-Fogarty v. Thomas Fogarty et al.S.D. New York · Apr 29, 2026same court · fake citations + civil rights

Linked evidence record

Damien Charlotin case archive

Publisher document archive
The recorded document is hosted in the upstream publisher archive.

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Public-record statuspublic record, not an allegation-only entry

Indexing eligibilitypublicly indexable with evidence status disclosed

Evidence-review statusprimary document verified

Published and maintained byManu Ayala · AI VortexIndependent legal AI risk intelligence

Evidence review recorded Jul 27, 2026

Source host classified Attribution boundary stated Limitations disclosed

Corpus checked Sep 10, 2026; latest tracked decision Sep 8, 2026. AI Vortex summarizes public records and does not replace the court document or legal research service.

Use this record

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Evidence boundary

The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.

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