New York S 1169 (New York AI Act)

The New York Artificial Intelligence Act establishes regulations for AI systems to protect civil rights and encourage safe AI innovation. Prohibits algorithmic discrimination by requiring developers and deployers of AI to prevent biases that disadvantage people based on protected characteristics. Obligates covered developers and deployers to conduct audits on high-risk AI systems, ensuring transparency and accountability, with the guidance of independent auditors. Enforces the prohibition...

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31 MAR 2026 · Court Case

Evgeny Yaroshevsky v. Karlin et al.

Misrepresented: Other | Plaintiff admitted using Google Gemini to obtain citations and failed to verify them before filing, contributing to the submission of fabricated and inaccurate authorities. || Fabricated: Case Law | Multiple authorities cited by plaintiff did not exist; defendants identified at least five nonexistent cases in the complaint and five in other filings and the Court confirmed some citations were fabricated. || False Quotes: Case Law | Numerous quotations attributed to cases could not be found in the opinions (Defendants identified ~13 instances; the Court found at least two such misquotes earlier).

Court: E.D. New YorkParty: Pro Se LitigantTool: Gemini

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. New York

30 MAR 2026 · Court Case

76 Route 6 Holdings Inc. v. Town of Yorktown, NY

False Quotes: Case Law | Plaintiff claimed McEachin v. McGuinnis contains language applying 'special solicitude' to civil rights plaintiffs; the Court determined McEachin contains no such language and admonished counsel. || False Quotes: Case Law | Plaintiff attributed to Goel v. Bunge the language that a defendant 'may not rely on statements in the documents for the truth of the matter asserted.' The Court found Goel contains no such language and admonished counsel.

Court: S.D. New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

30 MAR 2026 · Court Case

Beedemariam Kassaw v. Wal-Mart Corporation

Fabricated: Case Law | Plaintiff's January 2026 memorandum/sur-reply (Dkt. 79) included AI-generated 'hallucinated cases'—fabricated case citations; Court found apparent use of AI and ordered Dkt. 79 stricken.

Court: W.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: W.D. New York

25 MAR 2026 · Court Case

Fecteau v. Safety National Casualty Corporation

Fabricated: Legal Norm | Plaintiff quoted non-existent statutory language as if from 50 U.S.C. § 3936, asserting it tolled filing deadlines (the Court found the quoted language does not appear in § 3936). || False Quotes: Case Law | Plaintiff purported to quote existing opinions (e.g., Conroy v. Aniskoff and Gordon) but recited language that appears nowhere in those opinions; the Court found these to be false quotations.

Court: S.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

11 MAR 2026 · Court Case

Donte McClellon v. E. Rickard, Warden of FCI Otisville, et al.

Fabricated: Case Law | Petitioner’s reply cited at least three judicial opinions that do not exist; Magistrate Judge Moses identified these as likely AI-generated fabricated cases. || False Quotes: Case Law | Petitioner included fake quotations and citations attributed to judicial opinions; the court noted the presence of 'fake quotes and citations' consistent with AI hallucination.

Court: S.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

10 MAR 2026 · Court Case

Cartagena v. Dixon, Blackburn, and T.A. Blackburn Law, PLLC

Fabricated: Case Law | Brief filed by defendant's counsel contained multiple non-existent case citations and misstatements of law; court found pervasive 'hallucinated' cases and noted counsel attributed errors to use of 'Protégé' AI.

Court: S.D. New YorkParty: LawyerTool: LexisNexis Protégé

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

09 MAR 2026 · Working Paper

New York S 934 (Requires warnings on generative artificial intelligence systems)

Amends the general business law to require that owners, licensees, or operators of generative artificial intelligence systems clearly and conspicuously display a notice on the system's user interface indicating that the outputs of the generative AI may be inaccurate. Defines "generative artificial intelligence system" as AI models that emulate input data to generate synthetic content, including images, videos, and text. Specifies that an "artificial intelligence" system can make predictions...

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09 MAR 2026 · Court Case

M7 Indústria e Comércio de Compensados e Laminados v. U.S. Structural Plywood Integrity Coalition, et al.

False Quotes: Case Law | Plaintiffs' memorandum attributed this quoted passage to NYNEX Corp. v. Discon, but the Court found the quotation does not appear in that opinion. || False Quotes: Case Law | Plaintiffs' memorandum attributed this quoted passage to Int’l Railways of Cent. Am. v. United Brands Co., but the Court found the quotation does not appear in that opinion.

Court: S.D. New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

06 MAR 2026 · Court Case

Sai Malena Jimenez-Fogarty v. Thomas Fogarty

Fabricated: Case Law | Petitioner cited 'Hojan v. Steele, 875 F.3d 396, 400 (7th Cir. 2017)'; the court could not locate any case by that name and concluded the citation appears fabricated.

Court: S.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

06 MAR 2026 · Court Case

Nelson Lin v. The Honorable Jonathan H. Shim, et al.

Fabricated: Case Law | Plaintiff cited 'Hernandez v. Spitzer, No. 09-cv-3914, 2010 WL 11586928 (S.D.N.Y. Mar. 29, 2010)'; the court found that this case does not exist and rejected reliance on it. || Fabricated: Case Law | Editor's Note and court text indicate the opinion contains other incorrect or non-existent citation references preserved from the original record.

Court: S.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

04 MAR 2026 · Court Case

Jeri'yah Ford v. Troy City School District, et al.

Fabricated: Case Law | Plaintiff's Response cited unspecified Eighth Circuit and D. Kan. cases that opposing counsel and the Court could not locate; court concluded these were fabricated and ordered show cause. || Misrepresented: Case Law | Plaintiff mischaracterized Whitfield v. Notre Dame Middle Sch.; Court found the citation distinguishable and not supportive of Plaintiff's Title VI theory.

Court: N.D. New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: N.D. New York

24 FEB 2026 · Working Paper

New York A 6578 (AI Training Data Transparency Act)

Enacts the Artificial Intelligence Training Data Transparency Act in New York's general business law. Requires developers of generative AI models or services available to New Yorkers, from January 2027 onwards, to post data documentation used for AI training on their websites. Stipulates that this documentation must include sources and ownership of datasets, purpose-related data descriptions, data point details, and any proprietary or public domain status of datasets. Mandates disclosure ...

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10 FEB 2026 · Court Case

Matter of Zareh

Fabricated: Case Law | Brief contained numerous citation errors, including internally inconsistent and unverifiable citations; District Court concluded some citations were AI-generated and could not be verified. || Misrepresented: Case Law | Brief repeatedly misrepresented case law for propositions those cases did not support; District Court found ChatGPT described at least one cited case in the same erroneous manner.

Court: SC New YorkParty: LawyerTool: ChatGPT

⚠ Professional sanction imposed

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

09 FEB 2026 · Court Case

Ave. Capital Group, LLC v. Strum

Fabricated: Case Law | Court found counsel included a non-existent case citation in his memorandum and ordered show-cause re sanctions. || Fabricated: Case Law | Court found counsel included a non-existent (or incorrectly cited) Risucci decision; plaintiffs located a differently cited Risucci case that did not contain the quoted language.

Court: SC New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

05 FEB 2026 · Court Case

Flycatcher v. Affable Avenue

Fabricated: Case Law | Affable's motion to dismiss included numerous non-existent case citations generated by AI; Opposing counsel identified at least 13 fabricated cases and the Court found 14 of 60 citations to be fake. || Fabricated: Case Law | Proposed reply brief cited a nonexistent "Himmelstein v. Comcast of the D.C., LLC, 908 F.3d 49; aff'g 44 F. Supp. 3d 1 (D.D.C. 2012)"—citations that do not exist and were inconsistent with the intended New York Court of Appeals decision. || False Quotes: Case Law | Response to Order to Show Cause quoted a passage presented as from Mata v. Avianca but the quoted language was actually from a secondary article by Christopher F. Lyon; counsel failed to attribute the quote properly. || Misrepresented: Case Law | Reply brief and subsequent explanations showed misattributed/mismatched reporter citations (e.g., counsel relied on a Google Scholar result for Himmelstein that returned unrelated D.D.C. citations like 931 F. Supp. 2d 48), reflecting AI- or search-induced misrepresentation of the authoritative source.

Court: S.D. New YorkParty: LawyerTool: NotebookLM; vLex; Paxton AI

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

03 FEB 2026 · Court Case

1S REO Opportunity 1, LLC v. 223 Howard LLC

Fabricated: Case Law | Plaintiff cited Gustavia Home, LLC v. Rice, 2020 WL 4917915 (E.D.N.Y. Aug. 21, 2020), a Westlaw citation that does not exist; the number corresponds to Durrett v. IKO Indus., Inc. (Ky. Ct. App.), and the actual Gustavia Rice decision cited by court is 2016 WL 6683473 which states the opposite proposition.

Court: E.D. New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: E.D. New York

27 JAN 2026 · Court Case

Cassata v. Michael Macrina Architect, P.C.

Misrepresented: Case Law | Counsel cited Becker v Elm Air Conditioning Corp., 143 AD2d 965, 966 (2nd Dep't 1988) for a proposition the case does not support; court found mischaracterization of the holding. || Fabricated: Exhibits & Submissions | Counsel copied large portions of an unrelated brief (For a Financial Asset Securitization 2021, LLC v Teona, 2025 WL 334218) that itself had been criticized for non-existent cases; defendant adopted those unverified authorities without verification. || Fabricated: Case Law | Counsel cited Harris v Seward Park Housing Corp., 147 AD3d 589 (1st Dep't 2017), which the court found does not exist; citation originated from copied brief and was not verified. || Fabricated: Case Law | Counsel cited DiLorenzo v D.C. & D. Transp. Corp., 39 AD2d 950 (2nd Dept, 1972), which the court found does not exist. || False Quotes: Case Law | A quotation attributed to Harris v Seward Park Housing Corp. was included in the opposition but does not appear in any cited case and was found only in the copied brief and defendant's filing. || Misrepresented: Case Law | Counsel cited New York Univ. v Cont'l Ins. Co., 87 NY2d 308, 323 (1995) for a proposition the case does not support; court found the citation mischaracterized the precedent.

Court: SC New YorkParty: Lawyer

Fine: 10000 USD

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

12 JAN 2026 · Court Case

Wurtenberg v. The City of New York

Fabricated: Case Law | Plaintiff's papers relied on non-existent legal authority (fabricated cases); court found these authorities did not exist and attributed them to misuse of generative AI. || Misrepresented: Case Law | Plaintiff cited several existing cases that the court found did not stand for the propositions for which they were cited (misrepresented precedent).

Court: SC New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

08 JAN 2026 · Court Case

Deutsche Bank National Bank v. Jean LeTennier

Fabricated: Case Law | Submission of no less than 23 fabricated legal authorities across five filings, identified by plaintiff and confirmed by the court. || Fabricated: Case Law | Example fabricated citation submitted as 'Tishman Realty & Construction Co. v. Regan' with a New York citation that does not correspond to any reported state or federal case. || Misrepresented: Case Law | Misrepresentation of the holding of a real case—presented as dispositive for defendant when the cited case holds the opposite.

Court: SC New YorkParty: Lawyer

Fine: 10000 USD

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

07 JAN 2026 · Other

New York A 6767 (AI Companion Models)

Adds Article 47 to New York's general business law, governing AI companions. Defines key terms including "AI companion," "operator," and "emotional recognition algorithms." Prohibits operators from providing AI companions without protocols addressing user-expressed suicidal ideation, self-harm, physical harm to others, and financial harm, requiring notifications to crisis services. Requires operators to notify users at the beginning and every three hours during AI companion interactions th...

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01 JAN 2026 · Law / Act

2026 Chatbot Legislation — New York S-3008C [URL: https://www.nysenate.gov/legislation/bills/2025/S3008/amendment/C]

2026 chatbot legislation — Signed by Governor

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 6453B

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 768

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York SB 1962

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 3265

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 3356

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 3411

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York SB 934

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 6578A

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

01 JAN 2026 · Law / Act

New York AB 9654

New York legislation addressing AI systems with obligations for deployers, developers, and distributors. This legislation has been signed into law.

Primary legal sourceGenerative AI ·Data Privacy & ProtectionOfficial source · nysenate.gov ↗

31 DEC 2025 · Court Case

Burnett v. The City of New York

Fabricated: Case Law | Plaintiff's counsel cited a nonexistent case (Backus v. City of Rochester, 148 AD3d 1697 [4th Dept 2017]); the court reported it was unable to locate the case and ordered counsel to show cause why he should not be sanctioned.

Court: SC New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

30 DEC 2025 · Court Case

Labatt USA Operating v. Friends Beverage Group

Fabricated: Case Law | Court found defendants' opposition and cross-motion contained hallucinated/fabricated case citations generated by AI; filings were stricken.

Court: SC New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: SC New York

29 DEC 2025 · Court Case

Ng v. AmGuard Insurance Company, et al.

Fabricated: Case Law | Plaintiff cited 'Greyhound-Thermalink, Inc. v. B.U.R. Realty Corp., 42 A.D.3d 319, 320 (N.Y. 1st Dep’t 2007)', which the Court's research found does not appear to exist; Court warned about AI-generated fake citations.

Court: S.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

22 DEC 2025 · Court Case

Smith v. Clarence Smith et al.

Fabricated: Case Law | Plaintiff cited 'In re D.C. Judicial Conflicts of Interest, 540 F.2d 711 (D.C. Cir. 1976),' which the court found does not exist and is a fabricated citation. || Fabricated: Case Law | Plaintiff cited 'In re B.W., 352 F.3d 29 (2d Cir. 2003),' which the court determined does not exist and appears to be AI-generated. || Fabricated: Case Law | Plaintiff cited 'Wilkinson v. United States, 13 F.3d 855 (2d Cir. 1994),' which the court found to be nonexistent and unrelated to any real opinion at that reporter citation. || Misrepresented: Case Law | Plaintiff mis-cited Keir v. Schoeberl with an incorrect Westlaw citation ('2025 WL 1123456'); the court identified the correct citation as 2025 WL 437953, noting continued mis-citation of authority. || Misrepresented: Case Law | Plaintiff mis-cited Bennett v. Mnuchin with an incorrect Westlaw citation ('2020 WL 3214565'); the court noted the correct citation is 2020 WL 4432662, indicating miscitation rather than a substantive supporting authority.

Court: N.D. New YorkParty: Pro Se Litigant

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: N.D. New York

19 DEC 2025 · Law / Act

Responsible AI Safety and Education Act (RAISE Act)

New York's RAISE Act establishes transparency, incident-reporting, and safety requirements for developers of covered frontier AI models.

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19 DEC 2025 · Law / Act

New York S 7599 (Relates to automated decision-making by government agencies)

Amends the state technology law, education law, and civil service law to regulate automated decision-making by New York government agencies. Requires government agencies to disclose their use of automated decision-making tools on their websites annually. Mandates impact assessments for these tools, evaluating their objectives, potential biases, and cybersecurity risks, and ceasing use if they produce discriminatory outcomes. Instructs agencies to submit impact assessments to the gove...

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17 DEC 2025 · Court Case

Burlingame v. Argo Private Client Group, Ltd. et al.

False Quotes: Case Law | Counsel included quotations attributed to In re Vivendi Universal that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || False Quotes: Case Law | Counsel included quotations attributed to In re Parmalat that do not appear in that decision; the court flagged the quoted language as absent from the cited opinion. || Fabricated: Case Law | Plaintiff counsel cited 'Midlantic Nat’l Bank v. Havens, 1994 WL 760822, at *4 (S.D.N.Y. Dec. 27, 1994)' to support unjust enrichment; the court found that Midlantic does not appear to exist. || Misrepresented: Case Law | Plaintiff counsel cited In re Refco, 826 F. Supp. 2d 478, 512 (S.D.N.Y. 2011) as supporting unjust enrichment; the court found that Refco does not mention unjust enrichment and thus was misused.

Court: S.D. New YorkParty: Lawyer

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

16 DEC 2025 · Court Case

McMillian v. Zimmer US, Inc

Fabricated: Other | Plaintiff's counsel filed papers containing unspecified AI-generated hallucinations and inaccuracies (ECF Nos. 100-03); counsel conceded the errors and the Court imposed sanctions.

Court: S.D. New YorkParty: Lawyer

Fine: 9000 USD

Secondary evidenceHarms: Hallucination in legal filingsIssuing institution: S.D. New York

11 DEC 2025 · Law / Act

New York S8391 (Relates to the right of publicity)

Amends the New York civil rights law to define a "digital replica" as a computer-generated representation that is identifiable as the voice or likeness of an individual, used in various audio or visual works. Prohibits unauthorized use of a deceased personality's likeness, requiring prior consent for commercial use or the use of digital replicas, with liability for damages. Specifies exemptions for certain uses in plays, books, musical works, and other artistic or educational content. Clar...

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