NY Attorney’s Fake AI Citations Result in Warning, No Sanctions

A federal judge in Brooklyn declined to impose sanctions on an attorney who relied on fake, AI-generated cases in a brief arguing why her client’s discrimination case against the Academy Charter School shouldn’t be dismissed.

Magistrate Judge James M. Wicks of the US District Court for the Eastern District of New York admonished the attorney in a Thursday order. However, he said, the circumstances around the filing don’t “evince bad faith or willfulness, but rather severe carelessness.” Wicks noted that Gehi & Associates’ Suryia Rahman took responsibility for the mistake, and he commended the professionalism of all attorneys in the case.

“Counsel is, however, admonished and this Order should serve as a forewarning,” Wicks said.

The brief was written by a clerk who used Google for research, Rahman explained in a July 18 letter to the court. The attorney said she reviewed the draft but didn’t check the citations, in large part because of the “shock and grief” resulting from the unexpected death of her 39-year-old husband. Rahman has since taken bereavement leave and is “continuously meeting with medical and mental health professionals.”

“While the Court is aware of the serious implications that the misuse of AI-generated nonexistent caselaw presents, it is also mindful of the circumstances here which do not support any finding of bad faith,” Wicks said. The conduct “appears to be an isolated occurrence” on the part of Rahman, he added.

The case is Hall v. Academy Charter School, E.D.N.Y., No. 2:24-cv-08630, order 8/7/25.