Was Landberg v City of New York sanctioned over AI-generated citations?

Landberg v City of New York (App. NY (2d), June 24, 2026) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Monetary penalty: $8,000 (attorney) and $2,500 (firm), payable to the Lawyers' Fund for Client Protection of the State of New York. $10,500 in monetary penalties.

Which AI tool was involved in Landberg v City of New York?

The order in Landberg v City of New York does not identify a specific generative tool by name. The court treated the citations as the product of an unverified AI-assisted drafting workflow.

June 24, 2026 · AI sanctions database

Landberg v City of New York

Landberg v City of New York 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: App. NY (2d)
Date: June 24, 2026
Party: Lawyer
AI tool: Not identified in the order
Outcome: Monetary penalty: $8,000 (attorney) and $2,500 (firm), payable to the Lawyers' Fund for Client Protection of the State of New York
Penalty: $10,500 in monetary penalties.

Fine

What the record shows

After directing counsel to show cause under 22 NYCRR 130-1.1, the Appellate Division, Second Department imposed sanctions for an appellate brief that the court stated was prepared with the assistance of generative artificial intelligence and contained citations to nonexistent cases, purported Court of Appeals quotations contrary to actual law, and misrepresentations of what real cases held. Counsel submitted an affirmation taking full responsibility for the deficiencies and acknowledging that the nonexistent cases had been generated by AI. The court directed the attorney to pay $8,000 and the firm to pay $2,500 to the Lawyers' Fund for Client Protection of the State of New York, and noted that whether further disciplinary action is warranted is a matter for the Attorney Grievance Committee.

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 ↗ · CourtListener record ↗

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.

Run a free review Back to the full tracker →

Filed under · AI sanctions database · App. NY (2d)

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.

AI sanctions database · Sample report · Pricing · Run a scan