Mintvest Capital, LTD v. NYDIG Trust Company, et al.
D. Puerto Rico · Jun 23, 2025
What happened in this matter?
The court recommended Rule 11 sanctions against plaintiff's counsel for submitting filings containing fabricated case law and false quotations generated by the AI tool 'Claude'. The court recommended that counsel be ordered to pay the defendants' reasonable attorney's fees incurred due to the necessity of addressing these erroneous submissions.
- Why the court cared
- The court reasoned that counsel violated Rule 11(b)(2) by failing to ensure legal contentions were warranted by existing law. The court determined that while 28 U.S.C. § 1927 was inapplicable due to a lack of 'vexatious' intent, Rule 11 sanctions were appropriate to deter future conduct and compensate the opposing party for losses sustained due to the submission of non-existent and misleading authorities.
- Why it matters now
- Claude, ChatGPT, or any LLM still requires independent Westlaw verification — Rule 11 does not care which brand hallucinated.
Why this matter is tracked
Fabricated: Case Law | Non-existent case; 394 F. Supp. 2d 393 points to a different case (Díaz Rodríguez v. Torres Mártir, 394 F. Supp. 2d 389). Counsel admitted AI use. Outcome: Order to pay opposing counsel's fees. Plaintiff's counsel in the case of Mintvest Capital, LTD v. NYDIG Trust Company, et al., was found to have included numerous non-existent cases, false quotations, and misrepresented precedents in their filings. The errors were attributed to the use of the AI tool 'Claude' without proper verification. The court recommended sanctions under Rule 11, requiring the attorney to pay the defendants' attorney fees related to the faulty submissions. The court emphasized the need for attorneys to ensure the accuracy of citations, especially when using AI tools, to maintain professional standards.
Claude, ChatGPT, or any LLM still requires independent Westlaw verification — Rule 11 does not care which brand hallucinated.
Record details
Explore PROpen its source-linked jurisdiction page and related matters.What the record establishes about AI use
Counsel admitted using Claude for legal research.
Report and Recommendation on a motion for sanctions following a Show Cause Hearing.
Correction behavior is not separately verified in the current record.
Tracked discrepancy record
11 citation, quotation, or authority issues are recorded in the source dataset.
- Fabricated: Case Law | Non-existent case; 394 F. Supp. 2d 393 points to a different case (Díaz Rodríguez v. Torres Mártir, 394 F. Supp. 2d 389). Counsel admitted AI use.
- Fabricated: Case Law | Non-existent case; KLCE number and WL cite lead to unrelated cases. Counsel attributed to human/Google error.
- False Quotes: Case Law | Quoted language not found in the cited case; court noted ConnectU addresses amendment as of right, not prejudice/delay factors.
- Misrepresented: Case Law | Case cited for prejudice/delay amendment factors, but it concerns amendment as of right; misstates the case’s holding.
- Misrepresented: Case Law | Cited for permitting amendment to add federal claims after finding no diversity, but the case addresses personal jurisdiction and was dismissed.
- Misrepresented: Case Law | Cited to support permitting alternative pleadings, but the court did not address or endorse that concept.
- False Quotes: Case Law | Quoted language does not exist in the cited decision (WL cite also misstated). Counsel admitted AI use.
- False Quotes: Case Law | Quote attributed to Tambone is not in that case; originates from Texas Gulf Sulphur. Counsel admitted AI use.
Show 3 additional discrepancies
- Fabricated: Case Law | Non-existent case in Westlaw, Lexis, and CM/ECF. Counsel admitted AI use.
- False Quotes: Case Law | Quoted proposition not in the cited case. Counsel believed it true generally but conceded mis-citation and AI use.
- False Quotes: Case Law | Quoted language not found in the cited Second Circuit case. Counsel admitted AI use.
Questions this record answers
- What happened in Mintvest Capital, LTD v. NYDIG Trust Company, et al.?
- The court recommended Rule 11 sanctions against plaintiff's counsel for submitting filings containing fabricated case law and false quotations generated by the AI tool 'Claude'. The court recommended that counsel be ordered to pay the defendants' reasonable attorney's fees incurred due to the necessity of addressing these erroneous submissions.
- Why does Mintvest Capital, LTD v. NYDIG Trust Company, et al. matter for legal AI risk?
- Claude, ChatGPT, or any LLM still requires independent Westlaw verification — Rule 11 does not care which brand hallucinated.
- What does the public record establish about Mintvest Capital, LTD v. NYDIG Trust Company, 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 Mintvest Capital, LTD v. NYDIG Trust Company, 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.