US Second Circuit

Park v. Kim

Sanctioned · 30 January 2024

SectorLegal

CountryUnited States

Document typeAppellate reply brief

ConsequenceSanctioned

What was fabricated

Cited a non-existent decision (Matter of Bourguignon v. Coordinated Behavioral Health Servs.) that the attorney admitted was generated by ChatGPT.

What happened as a result

The Second Circuit referred attorney Jae S. Lee to its Grievance Panel for possible disciplinary proceedings.

Sources

https://reason.com/volokh/2024/01/30/second-circuit-refers-lawyer-for-disciplinary-proceedings-based-on-ai-hallucinated-case-in-brief/
https://law.justia.com/cases/federal/appellate-courts/ca2/22-2057/22-2057-2024-01-30.html

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