Mata v. Avianca — ChatGPT Fake Citations Sanctions Order (S.D.N.Y.)
S.D.N.Y. · Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023)
Two New York attorneys submitted a brief containing six fictitious case citations generated by ChatGPT. In June 2023 Judge P. Kevin Castel sanctioned them $5,000 each — the first formal federal sanction for AI-hallucinated legal citations, and the most-cited case in subsequent bar opinions on attorney AI use.
Technical detail
Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023). Rule 11 sanctions of $5,000 against attorneys Steven Schwartz and Peter LoDuca for submitting brief with six fabricated ChatGPT-generated case citations. Court emphasized attorneys' duty to verify citations regardless of source.
Who is protected: Courts and opposing parties against AI-fabricated legal authorities
Who must comply: Attorneys practicing in U.S. federal court
Key facts
| Jurisdiction | S.D.N.Y. |
|---|---|
| Level | Federal |
| Status | In effect |
| Protection strength | Moderate protection |
| Effective date | 2023-06-22 |
| Citation | Mata v. Avianca, Inc., 678 F. Supp. 3d 443 (S.D.N.Y. 2023) |
| Topics | consumer protection · AI disclosure and transparency · automated decision-making |
| Last verified | 2026-06-17 |
| Official source | Mata v. Avianca — CourtListener opinion ↗ |
More AI rules in S.D.N.Y.
- NYT v. OpenAI / Microsoft · Blocked / in litigation
- Authors Guild v. OpenAI · Blocked / in litigation
- CIR v. OpenAI · Blocked / in litigation
- Daily News v. OpenAI · Blocked / in litigation
- Intercept v. OpenAI · Blocked / in litigation
- UMG v. Udio · Blocked / in litigation
Related consumer protection rules elsewhere
- FTC Act Section 5 (unfair/deceptive AI) · In effect
- TAKE IT DOWN Act · In effect
- FCRA (AI in credit & background checks) · In effect
- ECOA / Regulation B (AI credit discrimination) · In effect
- COPPA + 2025 Rule (childrens data) · In effect
- TCPA (AI voice calls) · In effect
See something wrong or out of date? Submit a correction — every entry must carry a verifiable official source.