Pennantia, LLC v. Rose Cay Maritime, LLC
U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance
Verified May 5, 2026
- Citation
- Pennantia, LLC v. Rose Cay Maritime, LLC, No. 25-cv-5904 (SHS), Order (S.D.N.Y. Aug. 26, 2025) (ECF No. 56)
- Decided
- August 26, 2025
Summary
Counsel for defendant Dove Cay, LLC submitted an opposition to plaintiff Pennantia's motion for a preliminary injunction (ECF No. 32) that included two parenthetical quotations attributed to Crescent Towing & Salvage Co. v. M/V ANAX, 40 F.3d 741 (5th Cir. 1994), and General Electric Credit Corp. v. Drill Ship Mission Exploration, 668 F.2d 811 (5th Cir. 1982). Judge Sidney H. Stein read both decisions and confirmed neither contained the quoted language, nor could the language be located in any other federal or state court decision. The court further found the cited cases did not support the propositions for which they were offered.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction imposed in the order itself. Judge Stein directed Dove Cay to file a letter on or before August 29, 2025 explaining how the apparently nonexistent quotations ended up in its memorandum. The order does not name a specific AI tool, but the false-quotation pattern is consistent with generative AI hallucination.
Why does Pennantia, LLC v. Rose Cay Maritime, LLC matter for law firms using AI?
Pennantia is an unusually clean illustration of the false-quote variant of AI hallucination: real cases, correctly cited by reporter and pin-cite, but with parenthetical quotations that do not appear anywhere in the cited opinions or in any other reported decision. The trial judge caught it by reading the cited cases. For a managing partner, the operational lesson is that citation verification cannot stop at confirming the case exists; any quoted language pulled from a generative tool must be checked against the source text before filing.
Sources
Primary sources
Further reading
- Document mirror (Damien Charlotin hallucination database, Westlaw printout)
- Justia (legal aggregator)
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.
- Final disposition of the August 29 show-cause response and any later sanction order is not addressed in the verified PDF; the file reflects only the August 26, 2025 order to show cause.