Court Finds AI Hallucinations in Filing by Former State Senate Candidate
A former New York State Senate candidate and attorney, Tricia S. Lindsay, was sanctioned $2,500 by a federal court for submitting legal briefs containing numerous fabricated case citations. The court found that the citations were entirely made up and could not be attributed to simple errors or mischaracterizations. Lindsay failed to provide a credible explanation for the false citations, despite being ordered to show cause.
- ▪Tricia S. Lindsay filed legal memoranda containing multiple citations to nonexistent cases in the case Jimenez-Fogarty v. Fogarty.
- ▪Magistrate Gabriel W. Gorenstein ordered Lindsay to explain her drafting process but found her response vague and unconvincing.
- ▪The court determined that Lindsay's claimed manual verification process could not have occurred, as checking the citations would have revealed they were fake.
- ▪Lindsay attributed the false citations to typographical errors and database limitations, but the court found this explanation illogical and unsupported.
- ▪The court sanctioned Lindsay $2,500 for her misleading filings in the Southern District of New York.
Opening excerpt (first ~120 words) tap to expand
AI in Court Court Finds AI Hallucinations in Filing by Former State Senate Candidate Eugene Volokh | 5.2.2026 8:01 AM From Jimenez-Fogarty v. Fogarty, decided Wednesday by Magistrate Gabriel W. Gorenstein (S.D.N.Y.); Lindsay had run for the N.Y. State Senate in 2024: Tricia S. Lindsay, attorney for plaintiff Sai Malena Jimenez-Fogarty, responded to two motions to dismiss by filing a pair of memoranda of law that cited to numerous nonexistent cases. In response, the Court ordered Lindsay to show cause why she should not be sanctioned for her misleading filings. Upon consideration of Lindsay's response to these orders, we find that she should be sanctioned in the amount of $2,500.00 …. [T]wo briefs were signed by Lindsay, and each contained a number of fabricated citations.
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