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Public trackerEvidence checked Jul 23, 2026 · Latest decision Jul 21, 2026Public incidents are risk signals, not usage-adjusted rates
Evidence-linked corpus record: this page is generated from the structured public record and has a publication-readiness score of 80/100. It passed the source, context, and standalone-summary checks used for public indexing; individual legal editorial review is not represented.
Rotonde v. Stewart Title Insurance Co (1)
SC New York · May 6, 2025
NY / stateEditorial impact: lowpro setrial
Direct answer
What happened in this matter?
Outcome: Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff.
- Why the court cared
- Justice Jamieson noted that while the court is “sensitive to plaintiff's pro se status,” that does not excuse disregard of procedural rules or the submission of fictitious citations. The court emphasized that its prior decision in related litigation in 2022 undermined plaintiff’s tolling claims, and that Executive Order extensions during the COVID-19 pandemic did not rescue otherwise-expired claims. The hallucinated citations failed to salvage plaintiff’s fraud and tolling theories, and their use was treated as an aggravating—though not yet sanctionable—factor
- Why it matters now
- This matter connects pro se and trial involving AI (implied, unspecified) with Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff in SC New York, making it a concrete reference point for verification, supervision, and response controls.
Why this matter is tracked
Outcome: Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff.
AI Use
The court observed that “some of the cases that plaintiff cites… do not exist,” and noted it had “tried, in vain,” to find them. While no explicit AI use is admitted by the plaintiff, the pattern and specificity of the fabricated citations are characteristic of LLM-generated hallucinations.
Ruling/Sanction
The court dismissed all five causes of action—including negligence, tortious interference, aiding and abetting fraud, declaratory judgment, and breach of implied covenant of good faith and fair dealing—as either untimely or duplicative/deficient on the merits. It declined to impose sanctions but explicitly invoked Dowlah v. Professional Staff Congress, 227 AD3d 609 (1st Dept. 2024), and Will of Samuel, 82 Misc 3d 616 (Sur. Ct. 2024), to warn plaintiff that any future citation of fictitious cases would result in sanctions.
Key Judicial Reasoning
Justice Jamieson noted that while the court is “sensitive to plaintiff's pro se status,” that does not excuse disregard of procedural rules or the submission of fictitious citations. The court emphasized that its prior decision in related litigation in 2022 undermined plaintiff’s tolling claims, and that Executive Order extensions during the COVID-19 pandemic did not rescue otherwise-expired claims. The hallucinated citations failed to salvage plaintiff’s fraud and tolling theories, and their use was treated as an aggravating—though not yet sanctionable—factor.
Operational lesson
This matter connects pro se and trial involving AI (implied, unspecified) with Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff in SC New York, making it a concrete reference point for verification, supervision, and response controls.
Record details
New YorkSingle-state evidence scope
CourtSC New York
Jurisdictionstate
Circuit2nd Circuit
DateMay 6, 2025
AI
AI toolAI (implied, unspecified)
Party typePro Se Litigant
OutcomeMotion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff
Known amountNot recorded
Professional sanctionNo
Attribution boundary
What the record establishes about AI use
reported
AI (implied, unspecified) is recorded in the source dataset; confirm the basis in the linked document.
Procedural posture
Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff
Correction behavior
Correction behavior is not separately verified in the current record.
Questions this record answers
- What happened in Rotonde v. Stewart Title Insurance Co (1)?
- Outcome: Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff.
- Why does Rotonde v. Stewart Title Insurance Co (1) matter for legal AI risk?
- This matter connects pro se and trial involving AI (implied, unspecified) with Motion to dismiss granted in full; no sanction imposed, but court formally warned plaintiff in SC New York, making it a concrete reference point for verification, supervision, and response controls.
- What does the public record establish about Rotonde v. Stewart Title Insurance Co (1)?
- The record summarizes the outcome described in the linked public source. The recorded link is a legal-document or docket mirror. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
- Which source supports this Rotonde v. Stewart Title Insurance Co (1) summary?
- The recorded source is law.justia.com. It is classified as docket or legal-document mirror; 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.