Isaacs v. Novartis Pharmaceuticals Corporation
U.S. District Court, District of New Jersey · D.N.J. · New Jersey bar guidance
Verified May 5, 2026
- Citation
- Isaacs v. Novartis Pharmaceuticals Corp., No. 25-cv-13626 (GC) (JBD) (D.N.J. Nov. 3, 2025)
- Decided
- November 3, 2025
Summary
Plaintiff's counsel Brian M. Cige cited two non-existent cases, "Mitchell v. Gilmore, 74 F.3d 224 (4th Cir. 1996)" and "Feliciano v. Riverbay Corp., 576 F. Supp. 2d 370 (S.D.N.Y. 2008)," in a letter opposing federal jurisdiction in an ERISA-removal dispute. Mr. Cige acknowledged the citations were fabricated and explained that his client had supplied them after generating them with ChatGPT, and that he included them without independent verification while on vacation and rushing to respond to a pre-motion letter. Judge Georgette Castner found a Rule 11 violation, citing Benjamin v. Costco Wholesale Corp. and Wadsworth v. Walmart Inc. for the principle that submitting fake cases is itself a Rule 11 violation.
- AI tool:
- ChatGPT
What sanction did the court impose?
No monetary sanction. The court ordered Mr. Cige, within thirty days, to certify in writing that he completed the October 7, 2025 AI seminar hosted by Porzio Bromberg & Newman, for which he had self-registered after the show-cause order issued. The court declined to require additional CLE beyond that seminar, finding it sufficient to deter future conduct under Rule 11(c)(4).
Why does Isaacs v. Novartis Pharmaceuticals Corporation matter for law firms using AI?
Isaacs is one of the first published sanctions orders in which the fabricated citations originated not with counsel’s own AI use but with a client who had run ChatGPT and forwarded the output. Counsel imported the citations into a federal filing without verification, illustrating that a firm’s AI exposure now extends to unvetted research that walks in the door from clients. The court’s chosen remedy, certified completion of an AI-focused CLE in lieu of a monetary penalty, signals that prompt acknowledgment paired with proactive AI training can mitigate the financial sanction even where the Rule 11 violation is clear.
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.