76 Route 6 Holdings Inc. v. Town of Yorktown
U.S. District Court, Southern District of New York · S.D.N.Y. · New York bar guidance
Verified May 5, 2026
- Citation
- 76 Route 6 Holdings Inc. v. Town of Yorktown, No. 25-CV-693 (KMK), Dkt. 38 (S.D.N.Y. Mar. 30, 2026)
- Decided
- March 30, 2026
Summary
Plaintiff's counsel at Sichenzia Ross Ference Carmel LLP submitted an opposition brief that attributed a fabricated "special solicitude" quotation to McEachin v. McGuinnis, 357 F.3d 197 (2d Cir. 2004), and a separate fabricated quotation about judicial notice to Goel v. Bunge, 820 F.3d 554 (2d Cir. 2016). Judge Kenneth M. Karas found that neither quotation appears anywhere in the cited decisions, and noted that McEachin's actual holding (liberal construction for pro se litigants) had no application to this corporate plaintiff.
- AI tool:
- Unspecified generative AI
What sanction did the court impose?
No monetary sanction. Judge Karas admonished plaintiff's counsel in two footnotes, advising that counsel "must ensure the accuracy of all quoted materials" under Rule 11 and warning that counsel "runs the risk of sanctions" for fictitious quotations. The court cited Park v. Kim and a recent bankruptcy sanctions decision as the standard counsel had failed to meet. Motion to dismiss granted on the merits, with leave to amend within 30 days.
Why does 76 Route 6 Holdings Inc. v. Town of Yorktown matter for law firms using AI?
This case is notable because the hallucinations were not full fake citations to nonexistent decisions, but fabricated quotations attributed to real, properly-cited Second Circuit cases. A managing partner reviewing AI-assisted briefs cannot rely on citation-checkers alone: the cases existed and the cite formats were correct, yet the quoted language was invented. Verification at the quote level, not just the case level, is the lesson here. The court declined to impose monetary sanctions but put the firm on the record, which is itself a reputational mark in a publicly searchable opinion.
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.