Ramirez v. Humala
U.S. District Court, Eastern District of New York · E.D.N.Y. · New York bar guidance
Verified April 26, 2026
- Citation
- Ramirez v. Humala, No. 24-CV-242 (RPK) (JAM) (E.D.N.Y. May 13, 2025) (Order on Sanctions)
- Decided
- May 13, 2025
Summary
Attorney Lina Stillman of Stillman Legal, P.C. signed and filed a pre-motion response letter citing eight cases, four of which did not exist. Her paralegal, Abigail Ruiz, had generated the citations using "secondary tools, including public search resources and AI-based research assistants," and did not verify them; Ms. Stillman in turn did not independently verify the citations before filing. After an order to show cause, Judge Rachel P. Kovner found a Rule 11(b)(2) violation and inferred subjective bad faith from the complete absence of any citation-verification inquiry.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $1,000
What sanction did the court impose?
$1,000 sanction jointly imposed on Ms. Stillman and Stillman Legal, P.C., payable into the court registry within fourteen days. Ms. Stillman was also ordered to serve a copy of the order on her client, Abigail Ramirez, and file proof of service on the docket.
Why does Ramirez v. Humala matter for law firms using AI?
Ramirez v. Humala illustrates that delegating legal research to a paralegal does not delegate Rule 11’s verification duty. Judge Kovner explicitly held that an attorney’s reliance on a “diligent and trusted” non-attorney researcher is no substitute for reading the cited authorities, and the court inferred subjective bad faith from the absence of any independent inquiry. For managing partners, the order is a warning that AI-driven paralegal workflows must include an attorney-level citation check before any filing leaves the firm.