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AI VORTEXLEGAL AI RISK INTELLIGENCE
CASE BRIEF / REVIEW PACKETAV-CB-01HKQ3VGenerated September 10, 2026Evidence checked Sep 10, 2026
TRACKED PUBLIC MATTER

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
ADVISOR READOUT

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.

Why the decision-maker 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.

RECORDED ISSUES

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.
PRIMARY SOURCE

Damien Charlotin case archive

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

Open underlying source

A recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.

EVIDENCE BOUNDARY

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).

PRACTICAL REVIEW IMPLICATIONS

Controls suggested by the public record

  1. Verify the existence, citation, court, and precedential status of every authority before filing.
  2. Escalate unresolved verification failures before filing and preserve the responsible reviewer's signoff record.
  3. Apply the same source-checking controls to GPT-3.5 output as to any other research input.
  4. Read the linked source and subsequent docket history before relying on this record for legal work.