Hall v. The Academy Charter School
U.S. District Court, Eastern District of New York · E.D.N.Y. · New York bar guidance
Verified May 5, 2026
- Citation
- Hall v. The Academy Charter School, No. 2:24-cv-08630-JMW (E.D.N.Y. Aug. 7, 2025)
- Decided
- August 7, 2025
Summary
Plaintiff's counsel Suryia Rahman of Gehi and Associates filed an opposition brief, signed electronically by Naresh M. Gehi, that contained three fabricated case citations purporting to support the argument that charter schools are not subject to New York's notice of claim requirements: Laskowski v. Liberty Partners Restaurant Group Inc., Lindner v. Forest Hills Montessori School, and Matter of K.M. v. Bronx Charter School for Better Learning. None of the cases existed. Counsel attributed the failure to verify citations to a law clerk who used Google for research and to the recent unexpected death of counsel's spouse. Magistrate Judge James M. Wicks found the conduct violated Rule 11 but did not rise to subjective bad faith.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanctions imposed. Counsel was formally admonished, the order was directed to serve as a forewarning, and counsel was ordered to serve a copy of the Memorandum and Order on the plaintiff.
Why does Hall v. The Academy Charter School matter for law firms using AI?
Hall illustrates the discretionary leniency available to courts when hallucinated citations stem from carelessness rather than bad faith, particularly where personal hardship is documented. For managing partners, the case is a reminder that the Rule 11 violation is established the moment fabricated authority is filed: avoiding monetary sanctions in this instance turned on counsel’s candor, prior clean record, and tragic circumstances, none of which a firm can rely on as a governance strategy. The fabricated citations also originated from a non-attorney clerk’s unsupervised research, underscoring that delegation without citation verification creates the same exposure as direct AI misuse by the signing attorney.
Sources
Primary sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.