Was Park v. Kim sanctioned over AI-generated citations?

Park v. Kim (2nd. Cir. CA, January 30, 2024) is a documented matter involving citations that could not be verified against the reporters named. The recorded outcome was: Referral to Grievance Panel; client disclosure ordered. No monetary penalty in this order.

Which AI tool was involved in Park v. Kim?

The matter records ChatGPT as the generative tool associated with the unverified citations in Park v. Kim.

January 30, 2024 · AI sanctions database

Park v. Kim

Park v. Kim 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: 2nd. Cir. CA
Date: January 30, 2024
Party: Lawyer
AI tool: ChatGPT
Outcome: Referral to Grievance Panel; client disclosure ordered
Penalty: No monetary penalty in this order.

Bar referralProfessional sanction

What the record shows

Attorney Jae S. Lee admitted to citing a state court decision in her reply brief that the court found does not exist, and reported that she relied on ChatGPT to identify precedent without reading or confirming the cited decision. Finding the conduct fell well below the basic obligations of counsel, the court referred Attorney Lee to its Grievance Panel and ordered her to furnish a copy of the decision to her client.

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 · 2nd. Cir. CA

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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