Was Facey v. Fisher, Liane et al. sanctioned over AI-generated citations?

Facey v. Fisher, Liane et al. (Sup. Ct. N.Y., N.Y. County, September 15, 2025) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Motion to dismiss and for sanctions granted; legal-fee award (to be set); counsel ordered to disclose AI use. No monetary penalty in this order.

Which AI tool was involved in Facey v. Fisher, Liane et al.?

The order in Facey v. Fisher, Liane et al. does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

September 15, 2025 · AI sanctions database

Facey v. Fisher, Liane et al.

Facey v. Fisher, Liane et al. 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: Sup. Ct. N.Y., N.Y. County
Date: September 15, 2025
Party: Lawyer
AI tool: Not identified in the order
Outcome: Motion to dismiss and for sanctions granted; legal-fee award (to be set); counsel ordered to disclose AI use
Penalty: No monetary penalty in this order.

FineProfessional sanction

What the record shows

The court dismissed the amended complaint and granted defendants' motion for sanctions under 22 NYCRR 130-1.1, finding Plaintiff's counsel breached the duty of candor and filed a malicious, harassing complaint, and separately that the papers repeatedly cited cases that do not exist or do not stand for the propositions asserted (for example James v. City of New York and Xiong v. Knight), with quotations appearing nowhere in the cited decisions, which the court described as a sign of AI use. Defendants were awarded their legal fees on a forthcoming application, and counsel was ordered to file an affirmation disclosing whether AI applications or chatbots were used.

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 · Sup. Ct. N.Y., N.Y. County

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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