Appellate Court Imposes Sanctions For AI-Fabricated Citations

On Jan. 8, New York's intermediate appellate court in Deutsche Bank Nat'l Trust Co. v. LeTennier found defense filings contained at least 23 fabricated cases and concluded counsel used generative AI without adequate oversight. The court imposed $5,000 plus an additional $2,500 sanction on counsel and $2,500 on the defendant, totaling $10,000, and emphasized attorneys must fact-check AI-assisted submissions. The decision establishes appellate-level deterrence against AI-driven frivolous filings.