Mata v. Avianca, Inc.
Court sanctionU.S. District Court, Southern District of New York · S.D.N.Y. · Decided June 22, 2023
- Citation:
- Mata v. Avianca, Inc., No. 22-cv-1461 (PKC) (S.D.N.Y. June 22, 2023)
- AI tool:
- ChatGPT
- Sanction amount:
- $5,000
What happened
Attorneys Steven Schwartz and Peter LoDuca submitted a brief citing six nonexistent court decisions generated by ChatGPT. When opposing counsel identified the citations as fabricated, the attorneys initially maintained they were real. Judge P. Kevin Castel imposed sanctions after finding the attorneys had failed to verify AI-generated citations before filing.
Outcome
$5,000 sanction imposed jointly and severally against the law firm Levidow, Levidow & Oberman and attorneys Schwartz and LoDuca. Attorneys ordered to send copies of the sanctions order to the parties in each fabricated case.
Mata v. Avianca is the canonical AI hallucination sanctions case. It drew widespread coverage and established the precedent that attorneys are responsible for verifying AI-generated citations before filing. The case is frequently cited by bar associations, malpractice carriers, and courts in subsequent AI-related orders.
Primary sources
Last verified: April 23, 2026. Verify against primary sources before relying on this in a filing.