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Federal Court Rebukes Repeat Offender Lawyer Over AI-Hallucinated Case Citations

July 13, 2026 at 13:27 EDT

Policy & Regulation
Foundation Models

A New York federal magistrate judge has struck a lawyer's court filing and referred him for discipline after finding it riddled with AI-generated citations that misquoted real cases — the latest sanction against an attorney with a documented history of similar misconduct.

July 1, 2026 · Dixon v. Cartagena · S.D.N.Y.

Repeat AI-Citation Offender Faces Discipline Referral

A federal magistrate judge struck an attorney's brief after finding it stuffed with AI-generated citations that misquoted real cases — citing a "complete disregard" for his duty to make accurate representations to the court.

quoted passages that did not match their cited sources

3rd

sanction for similar AI-citation misconduct by the same lawyer

Rule 11

basis for penalties on unverified filings

A Pattern of Sanctions — Escalating Each Time

Prior penalties did not stop the conduct — so the court escalated to a disciplinary referral.

~$5,000

Jun 2025 · W.D. Pa.

→

Sanction

Dec 2025 · D.N.J.

→

Struck + Referred

Jul 2026 · S.D.N.Y.

Immediate Consequences

Brief Stricken

Opposition filing removed from the record

Sanctions Ordered

Separate penalty imposed by the court

Grievance Review

Committee may impose professional discipline

The Bedrock Rule

Text inside quotation marks must accurately reproduce the original source. AI is an aid — never a substitute for a lawyer's verification.

The Lawyer's Defense — Rejected

Claims that passages were "paraphrases" and that opponents did the same were found unpersuasive and poorly supported.

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