Watch These Judges Rip Into Lawyers For Citing Cases That Don't Exist

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AI<br>Watch These Judges Rip Into Lawyers For Citing Cases That Don't Exist

Samantha Cole

Jun 4, 2026<br>at 10:33 AM

“It's striking, concerning, disappointing, and saddening to think that members of the bar would forward cases to a court that don't exist, and to think that the lawyers on the other side of that didn’t read it for whatever reason, didn’t check it.”

Screenshots via NY courts / collage by 404 Media

In the last few years, we’ve heard case after case where attorneys used generative AI and were caught including fake citations, quotes, and other major errors in their filings. This generally plays out in dockets, where their opponents or judges spot them and, in the polite language of the courts, scold them for wasting everyone’s time and being a disgrace to the legal profession. Sometimes, this results in serious sanctions. But it's always entertaining to read.<br>In an appeal hearing last month, a court’s live stream captured this happening on camera in real time, with an attorney caught for likely using AI-fabricated citations. On May 20, in the Supreme Court of the State of New York Appellate Division, Justices Valerie Brathwaite Nelson and Hector LaSalle reamed out that lawyer and his opposing counsel for more than 20 minutes, calling the situation “striking, concerning, disappointing, and saddening.”<br>The plaintiff in the case, Judith Landberg, is suing the city of New York after she tripped on some askew bricks on the sidewalk that were pushed up by tree roots. In that hearing, her lawyer, Michael Sanders, was attempting to argue the definition of a sidewalk. The full video is here, and the portion about fake citations begins a little after the 19 minute mark.<br>“In preparing for this oral argument and reviewing the brief of appellant, it came to the attention of the court that the brief submitted by plaintiffs cites at least three cases that appeared to be fictitious,” Nelson said. “None of these cases, nor the quoted language, appears to exist.”<br>Not only did Sanders cite cases that don’t exist, Nelson said, he cited 10 other cases that appear to misrepresent the law. “How do you respond?” Nelson asked.

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Sanders instantly started digging a hole, saying that he wasn’t prepared to speak on those specific citations. Nelson promptly cut him off. “Before you go any further,” she said, “let me point out to you that Rule 3.3 A of the rules of professional conduct indicates that a lawyer shall not knowingly make a false statement of fact or law to a tribunal, or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer.”<br>He stammered. “If there's any citations that are incorrect, my deepest apologies,” he said.<br>“Where did you get them from?” LaSalle asked.<br>“I don't know what these cases were specifically,” Sanders said.<br>LaSalle and Nelson grilled Sanders for several more minutes about the citations and where he got them. The judges didn’t bring up generative AI specifically, but considering the growing epidemic of lawyers including fake citations while using AI to draft arguments and appeals, it’s almost certainly what they’re alluding to. Attorneys caught using AI in other cases have blamed everything from head colds to being in a rush, to paralegals. Judges, in general, seem sick of it.<br>“Just so you know, because I don't want you to dig a bigger hole here, you're citing principles that don't exist,” LaSalle said. “Let me tell you something. We saw this last week. I was hopeful that, in preparation for today, that you were going to read this and say, 'Oops, we made a mistake, Judge.’ It happens sometimes, right? That's what I was hoping for. We didn't get that. Should we give you some time right now to go look these cases up?”

Sanders replied that it would probably take longer than 15 minutes. They went back and forth, with LaSalle and Nelson taking turns trying to impress upon Sanders that this is very, very bad.<br>Ross Friscia, the attorney representing the owner of the property that faces the sidewalk, stood up before the judges next. He started to speak, but LaSalle wasn’t finished with the dressing-down. “He’s raising a court of appeal standard that doesn’t exist,” LaSalle said, interrupting Friscia. “He was using it as a component of his argument, and you didn't think you should bring it to our attention?”<br>“I didn't notice in particular that the principle of law that he was citing was incorrect,” Friscia said.<br>“I'm sorry, I'm going to give you every opportunity to make your argument,” LaSalle said. “But I'm befuddled. I honestly am. I'm absolutely—and I'm not here to—lawyers make mistakes. It's not an easy profession. I don’t want to...