New York · federal district court · 2026

Superb Motors Inc. v. Deo

District Court, E.D. New York, 20 April 2026 to 30 April 2026. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.

Case record · E.D.N.Y

  1. Court. District Court, E.D. New YorkCOURT
  2. Level. federal district courtLEVEL
  3. Dates. 20 April 2026 to 30 April 2026DATED
  4. Docket. No. 2:23-cv-06188DOCKET
  5. Judge. James M. WicksJUDGE
  6. Documents. 2 documents, 11 passages quoted belowON FILE
  7. Source. CourtListenerSOURCE

Retrieved · the text below was read from the source documents on that day.

What the court wrote

The passages in which the court addresses the fabricated authority, verbatim, by document. A bracketed ellipsis marks where a passage was cut for length; nothing else is changed.

Docket entry 492, 30 April 2026 · source · PDF · 9 pages

Docket text. MEMORANDUM AND ORDER. For the reasons set forth in the attached Memorandum and Order, the Court imposes a monetary sanction of $1,500 upon attorney Harry R. Thomasson, Esq., that must be paid by him into the Registry of this Court on or before May 15, 2026. So Ordered by Magistrate Judge James M. Wicks on 4/30/2026. (ELR) (Entered: 04/30/2026)

Thomasson 3280 Sunrise Highway, Ste Box 112 Wantagh, NY 11793 Defendant Appearing Pro Se No appearances by other Parties WICKS, Magistrate Judge: While this case has had its fair share of discovery disputes and countless motion practice, the Court is now confronted with an issue that attorneys should never want to be a part of: the use of generative artificial intelligence (“AI”) to assist in the drafting of legal papers that results in the creation of a legal submission containing citations to fictitious or non-existent legal authority – commonly referred to as “hallucinated” or fake case citations.

Thomasson, Esq. (“Thomasson”) relied upon AI-generated content that created fictitious legal citations. That conduct unquestionably violated Federal Rule of Civil Procedure 11.

The Court issued a sua sponte Order to Show Cause (“OSC”) on April 20, 2026, directing Thomasson to show cause, in writing, why the Court should not impose sanctions upon him for the conduct indicated in Superb Plaintiffs' 1 reply brief at ECF No. 372 for the fabricated cites in Thomasson's opposition filed at ECF No. 353.

(ECF No. 353.) However, that opposition contained non-existent case citations. While Superb Plaintiffs pointed to only one case, “In re Amica Mut.

Supp. 3d at 460 (same and imposing sanctions under Rule 11 for the use of non-existent judicial opinions). NYRPC § 1.1 states that “[a] lawyer should provide competent representation to a client.

Ct. 2026) (citing id.) Unfortunately, reliance on AI-generated hallucinated cites in legal briefs remains a concern for the Courts, notwithstanding the years and number of publicized cases on the topic. See Hall, 2025 WL 2256653, at *4 (“Regrettably, the number and regularity with which courts have been faced with hallucinations in court filings continues to rise both in this country and abroad.”) The number of court filings with non-existent cases is rising rapidly.

See Hall, 2025 WL 2256653, at *4 (“Regrettably, the number and regularity with which courts have been faced with hallucinations in court filings continues to rise both in this country and abroad.”) The number of court filings with non-existent cases is rising rapidly. See Damien Charlotin, AI Hallucination Cases, (Apr. 29, 2026) https://www.damiencharlotin.com/hallucinations/ (database tracking legal decisions “in cases where generative AI produced hallucinated content,” evidencing 919 cases to date).

3d 251, 258 (S.D.N.Y . 2024) (collecting cases) (“There is no doubt that sanctions can be imposed on at least some of these grounds for the citation to non-existent cases); Cartagena v. Dixon, No.

Docket entry, 20 April 2026 · source

Docket text. ORDER TO SHOW CAUSE. Pro se Defendant Harry Thomasson ("Thomasson") is directed to show cause, in writing, on or before April 24, 2026, why the Court should not impose sanctions upon Thomasson, a pro se Defendant, who is also an attorney, for the conduct indicated in Superb Plaintiffs' reply brief at ECF No. 372 for the fabricated legal authority contained in Thomasson's opposition (ECF No. 353) of "a non-existent case apparently aided by artificial intelligence." See Park v. Kim, 91 F.4th 610, 613-16 (2d Cir. 2024) (referring counsel to the grievance committee for the use of non-existent judicial opinions through artificial intelligence); Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 466 (S.D.N.Y. 2023) (imposing sanctions for the use of non-existent judicial opinions). So Ordered by Magistrate Judge James M. Wicks on 4/20/2026. (JAF)

Pro se Defendant Harry Thomasson ("Thomasson") is directed to show cause, in writing, on or before April 24, 2026, why the Court should not impose sanctions upon Thomasson, a pro se Defendant, who is also an attorney, for the conduct indicated in Superb Plaintiffs' reply brief at ECF No. 372 for the fabricated legal authority contained in Thomasson's opposition (ECF No. 353) of "a non-existent case apparently aided by artificial intelligence." See Park v.

Kim, 91 F.4th 610, 613-16 (2d Cir. 2024) (referring counsel to the grievance committee for the use of non-existent judicial opinions through artificial intelligence); Mata v. Avianca, Inc., 678 F.

3d 443, 466 (S.D.N.Y. 2023) (imposing sanctions for the use of non-existent judicial opinions). So Ordered by Magistrate Judge James M.

What the text mentions

Pattern matches on the documents' text. Each line is a fact that the text contains the words, not a finding about the case.

Where this fits

This page is a record, not legal advice. It quotes the documents on file and lists what their text mentions. Read the decision at the source before relying on it, and check whether a later order changed it.

More from District Court, E.D. New York, from New York, or from 2026. The whole record is at court decisions on AI-hallucinated citations.

Every case in this record shares one cause: a citation reached a court without anyone opening it. What a citation gate is explains the mechanism that makes that impossible by construction; how to check an AI citation in five minutes is the manual version; the sanctions record is the essay this table grew out of.

Show me on one of my files →

This case is about a cite nobody opened. See a cite checked against the record before it renders, on your own file.

Show me on my files