Minhye Park v. Hon. Barrington D. Parker, et al.
S.D. New York · Jul 15, 2026
- Jurisdiction
- federal
- Court
- S.D. New York
- Record ID
- minhye-park-v-hon-barrington-d-parker-et-al-2026-07-15
- Observed outcome
- The court dismissed the plaintiff's claims, upholding the validity of the Second Circuit's disciplinary referral of the attorney.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
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.
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.
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.
Failure modes and consequences
- Fake Citations
- Bar Referral
- Civil Rights
- Trial
- AI attribution
- Explicitly Recorded
- Recorded tool
- GPT-3.5
- Known monetary consequence
- Not recorded
- 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.
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 opinion identifies GPT-3.5 as the source of the fabricated citation.
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.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
- Apply the same source-checking controls to GPT-3.5 output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.