M7 Indústria e Comércio de Compensados e Laminados Ltda. v. U.S. Structural Plywood Integrity Coalition
U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance
Verified April 26, 2026
- Citation
- M7 Indústria e Comércio de Compensados e Laminados Ltda. v. U.S. Structural Plywood Integrity Coalition, No. 1:25-cv-04568 (PKC) (S.D.N.Y. Mar. 9, 2026)
- Decided
- March 9, 2026
Summary
Plaintiffs' counsel Michael Stanton filed a memorandum (ECF 23) containing two purported quotations from federal cases that did not appear in the cited opinions, including a fabricated quote attributed to NYNEX Corp. v. Discon, Inc., 525 U.S. 128, 135 (1998), and a fabricated quote attributed to International Railways of Central America v. United Brands Co., 532 F.2d 231 (2d Cir. 1976). Senior District Judge P. Kevin Castel, the same judge who decided Mata v. Avianca, ordered Stanton to file a declaration explaining how the fake quotes appeared in the brief and to certify that he has personally read every case cited in the memorandum, verified each citation and quotation, and confirmed each remains good law.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
Order to show cause requiring counsel Michael Stanton to file, within fourteen days, a declaration explaining the fabricated quotations and a full certification that he has personally verified every citation in the memorandum. Court reserved decision on further sanctions pending Stanton's response.
Why does M7 Indústria e Comércio de Compensados e Laminados Ltda. v. U.S. Structural Plywood Integrity Coalition matter for law firms using AI?
This order is notable because Judge Castel, who presided over Mata v. Avianca in 2023, expressly invoked Mata in scolding counsel for fabricated quotations nearly three years later. The order frames fake quotations as a systemic threat to judicial trust and signals that, after years of public reporting, courts are unwilling to treat hallucinated authority as an excusable error of process. For managing partners, the takeaway is that brief-level quotation checking, not just citation existence checking, is now part of the duty of candor floor.
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.