Which AI tool was involved in 1S REO Opportunity 1, LLC v. 223 Howard LLC?

The order in 1S REO Opportunity 1, LLC v. 223 Howard LLC does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

February 3, 2026 · AI sanctions database

1S REO Opportunity 1, LLC v. 223 Howard LLC

1S REO Opportunity 1, LLC v. 223 Howard LLC is one matter in the Veritas record of US court proceedings involving AI-generated citations that could not be verified against the reporters named. The summary below is drawn from the underlying court document, linked at the foot of this page.

Court: E.D. New York
Date: February 3, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: No sanction; citation noted in opinion
Penalty: No monetary penalty in this order.

What the record shows

In a footnote, the court noted that Plaintiff cited 'Gustavia Home, LLC v. Rice, 2020 WL 4917915 (E.D.N.Y. Aug. 21, 2020),' which the court stated does not exist, that Westlaw citation corresponds to an unrelated Kentucky Court of Appeals decision. The court granted Plaintiff's motion for summary judgment and imposed no sanction for the citation.

This entry reflects the court document as filed. The citations at issue could not be located in the reporters named at the time of the order. The reading here is descriptive of the public record and is not legal advice.

Source documents

Primary court document ↗

The test this filing did not run

Every matter in this record shares one mechanism: a citation that did not resolve to an opinion in the reporter named, in a brief that was filed before any verification step ran. Veritas runs that step. The Filing Risk Scanner extracts each citation, resolves it against reporter and public-record sources, and returns a verdict on each one — located, partial, or not located in reporter — before the brief is signed.

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Filed under · AI sanctions database · E.D. New York

About this publication

Veritas is a pre-filing citation verification platform for law firms and in-house counsel. Every post on the audit log is written by the Veritas editorial team and cross-checked against the underlying sanctions order, standing order, or published opinion it references. Reporter citations are read in their named volumes. Quotations from court orders are checked against the docket.

The product was built by Andrew Zoll, founder of Veritas, who tracks generative AI sanctions in federal and state courts and turns each documented failure mode into verification logic the scanner runs. Veritas was built after the canonical Mata v. Avianca sanctions order made the verification gap a published failure mode of the bar.

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