Idehen v. Stoute-Phillip
Civil Court of the City of New York, Queens County · N.Y. Civ. Ct., Queens Cty. · New York bar guidance
Verified May 5, 2026
- Citation
- Idehen v. Stoute-Phillip, 2025 NY Slip Op 51211(U), No. LT-305376-23/QU (N.Y. Civ. Ct., Queens Cty. July 29, 2025)
- Decided
- July 29, 2025
Summary
Petitioner-landlord's counsel Innocent O. Chinweze submitted an April 21, 2025 affirmation opposing a motion to dismiss that cited seven nonexistent cases generated by Microsoft Copilot. After Judge Kimon C. Thermos ordered Chinweze to show cause why he should not be sanctioned, Chinweze filed a 94-page response that included the fabricated "LaSalle Bank v. Nomura" case (purportedly to be replaced by the real Liggett v. Lew Realty LLC, 42 NY3d 415 (2024), which did not stand for the cited proposition) and misrepresented Pusatere v. City of Albany along with several other unrelated decisions, with case summaries bearing AI-generated disclaimers. Chinweze first blamed his computer being "hacked" then retracted that explanation after lunch.
- AI tool:
- Microsoft Copilot
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 sanction payable to the Lawyers' Fund for Client Protection within 25 days, plus mandatory referral to the State of New York Grievance Committee for the Second, Eleventh & Thirteenth Judicial Districts. The court found Chinweze's conduct escalated from frivolous to egregious misconduct implicating his honesty, trustworthiness, and fitness to practice law.
Why does Idehen v. Stoute-Phillip matter for law firms using AI?
Idehen is the first reported New York state-court decision to both monetarily sanction an attorney for AI-fabricated citations and refer that attorney to a grievance committee, going further than the prior New York state-court hallucination cases (Matter of Samuel, Rotonde, and Dowlah), which stopped at warnings or unimposed findings of frivolousness. For managing partners, the case underscores two compounding risks: the underlying Copilot-generated fake cases drew a modest $1,000 sanction in line with federal AI-hallucination penalties, but the attorney’s lack of candor at the hearing, including a retracted “my computer was hacked” defense, was what triggered the bar referral. Firms documenting AI-use policies may wish to consider how their incident-response procedures handle the moment after a hallucination is detected, since post-discovery conduct can matter more to discipline than the initial mistake.
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.