Case Type
Non-payment
Housing Type
Other
Court
Civil Court of the City of New York
County
Queens County (Queens)
L&T / Index / Case / Docket / Clerk's Number
LT-305376-23/QU
Slip Opinion Number
2025 NY Slip Op 51211(U)
Petitioner
Happiness Idehen, Felix Ogieva
Respondent
Gloria Stoute-Phillip, "JOHN DOE", "JANE DOE"
Judge
Thermos, Kimon C
Decision/Order Date
2025-07-29
Posture
Other
Disposition
Case Dismissed/discontinued
Winner
Tenant Substantially Won
Synopsis
An attorney for the landlord was sanctioned for submitting motion papers that cited numerous non-existent cases, which were determined to be the result of using an AI-based research tool without proper verification. The court found this to be frivolous conduct under 22 NYCRR § 130-1.1, warranting a $1, 000 sanction and a referral to the State of New York Grievance Committee. This decision highlights the legal risks and ethical obligations associated with using artificial intelligence for legal research, emphasizing the duty of an attorney to verify all citations and factual statements. The attorney's subsequent filing of a 94-page document with real but irrelevant cases further supported the court's finding of frivolous conduct.
Keywords
Sanctions; Citing Non-Existent Cases
Recommended Citation
"Idehen v. Stoute-Phillip" (2025). All Decisions. 1886.
https://ir.lawnet.fordham.edu/housing_court_all/1886
