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 75, 30 September 2026 · source · PDF · 11 pages
Docket text. ORDER denying 67 Motion for Sanctions. For the reasons stated in the attached Order, Plaintiff's motion for sanctions is denied as being without merit. Ordered by Chief Mag. Judge Vera M. Scanlon on 9/30/2026. (JAA)
67. Plaintiff, through attorney Tyrone Blackburn (“Attorney Blackburn”), seeks sanctions against Attorney Charles for using two allegedly fabricated citations in his filings at ECF Nos. 54 and 63.
67. Plaintiff alleges that Attorney Charles relied on “fabricated or materially misattributed citations” in his oppositions to the motion to vacate judgment, which were filed at ECF Nos. 54 and 63.
67-1 at 1-2. Plaintiff seeks monetary sanctions “in an amount sufficient to deter future misconduct and to compensate Plaintiff for the reasonable attorney’s fees and costs incurred in identifying and responding to the fabricated and misattributed citations.” ECF No. 67 at 1.
Plaintiff requests the following additional relief: (1) 3 striking all arguments in ECF Nos. 54 and 63 that are supported exclusively by fabricated legal authority; (2) directing Attorney Charles to file a sworn declaration regarding his AI usage; (3) directing Attorney Charles to certify that all legal citations have been independently verified in all future filings for two years; and (4) referring this matter to the Grievance Committee for investigation of Attorney Charles’s conduct. Id. at 1-2.
Id. at 1-2. Plaintiff alleges Attorney Charles’s first fabrication was a citation to “Mpala v. Segarra, 715 Fed.
Plaintiff argues the Mpala decision does not support Attorney Charles’s argument because it “addressed a Rule 60(b)(1) motion based on an alleged miscommunication between the plaintiff and his prior attorney—not a Rule 60(d)(3) fraud on the court claim.” Id. Plaintiff alleges Attorney Charles’s second fabrication was a citation to “Linkco Inc., v. Naoyuki Akikusa, 357 Fed Appx.
Id. at 6- 7. Plaintiff contends the Court should find bad faith because Attorney Charles used “two separate fabricated citations across two independent submissions filed ten weeks apart, each citing a real reporter location belonging to an unrelated decision, and each assigning to that 1 The case reported at 715 F. App’x 84 is Johnson v.
4 location a legal proposition that the actual decision does not contain.” Id. at 10. In an accompanying affidavit, Attorney Blackburn says he expended at least ten hours “investigating and responding to the fabricated and misattributed citations in ECF Nos. 54 and 63,” for a total of $7,500 in fees and costs “attributable solely to addressing Mr.
Docket entry 74, 18 September 2026 · source · PDF · 4 pages
Docket text. RESPONSE in Opposition re 67 First MOTION for Sanctions Against Fred V. Charles, Esq. and Charles Law, P.C. for citing two AI generated cases. One fabricated case was cited in a the document filed at ECF 54, and the other fabricated case was cited in a the document filed at ECF filed by Olivia Nantongo. (Charles, Fred) (Entered: 09/18/2026)
No. 68), contends that I fabricated or materially misattributed four (4) cited cases in total in two separate filings at Dkt. Nos.
67- 2), in contradiction of Mr. Blackburn’s Affidavit, contends that I fabricated two (2) cases, not four (4). After reviewing Mr.
After reviewing Mr. Blackburn’s submissions, I immediately recognized that Blackburn’s allegations of fabricated case law as false because I do not use A.I. to draft submissions to court. The truth is that Mr.
Blackburn used an A.I. chatbot to manufacture obviously false accusations of fabrication. f Mr. Blackburn had bothered to actually read my submissions, or even his own submissions, he would have recognized that two (2) of the allegedly fabricated cases appear nowhere in my documents. Even worse, Mr.
Even worse, Mr. Blackburn submitted a sworn statement to this Court that he spent “ not less than 10 hours” to verify four non-fabricated cases. Mr.
Mr. Blackburn contends that his “not less than ten (10) hours” of verifying my citations revealed the following fabricated case law: Mpala v. Segarra, 718 Fed.
No. 63, I used “357” instead of “367.” These are two (2) admitted typographical errors that do not amount to fabrication of cited case law. For clarification of what it means to fabricate, and for Mr.
17, 2026). The first two (2) cases are not fabricated because Mr. Blackburn attached both opinions to his Affidavit (they do exist).
Docket entry 67, 22 April 2026 · source · PDF · 14 pages
Docket text. First MOTION for Sanctions Against Fred V. Charles, Esq. and Charles Law, P.C. for citing two AI generated cases. One fabricated case was cited in a the document filed at ECF 54, and the other fabricated case was cited in a the document filed at ECF 63 by Olivia Nantongo. (Attachments: # 1 Proposed Order Proposed Order, # 2 Memorandum in Support Memorandum of Law) (Blackburn, Tyrone) (Entered: 04/22/2026)
Federal Rule of Civil Procedure 11 ARGUMENT I. THE TWO FABRICATED CITATIONS WARRANT SANCTIONS UNDER THE COURT'S INHERENT AUTHORITY a. The Fabrications Are Established Beyond Dispute b.
P. 11(c)(2) Other Authorities • New York Rule of Professional Conduct 3.3(a)(1) • New York Rule of Professional Conduct 8.4(c) 4 PRELIMINARY STATEMENT This motion arises from a pattern of conduct that strikes at the foundational integrity of the judicial process: the submission to this Court of fabricated legal citations in not one, but two successive court filings. Fred V.
54) and a memorandum of law on April 17, 2026 (ECF No. 63), each of which cited, as binding or persuasive Second Circuit authority, a case that does not exist at the citation given. In each instance, the reporter volume and page number cited by Mr.
In each instance, the reporter volume and page number cited by Mr. Charles belong to an entirely unrelated decision from a different circuit addressing a wholly different area of law — the telltale signature of AI-generated citation hallucination. The Court should understand the context in which these fabrications arise.
It is the judgment procured through those forged documents — filed directly with this Court and resulting in entry of a clerk's judgment — that Plaintiff seeks to vacate, and it is in opposing that motion that Mr. Charles submitted the fabricated citations addressed herein. What makes Mr.
It is the unverified output of an AI drafting tool submitted to this Court as though it were binding legal authority. The submission of fabricated citations to a federal court is not a technical irregularity. It is a breach of the duty of candor owed to this tribunal, an unreasonable multiplication of proceedings within the meaning of 28 U.S.C. § 1927, and an abuse of the judicial process that warrants the exercise of this Court's inherent sanctioning authority.
C. The Pattern Confirms Willful Conduct or Reckless Indifference Two fabricated citations filed in two separate submissions over a ten -week period cannot be attributed to inadvertence. The inference of bad faith or reckless indifference is further compelled by the most remarkable feature of this record: in the very memo randum of law (ECF No.
The inference of bad faith or reckless indifference is further compelled by the most remarkable feature of this record: in the very memo randum of law (ECF No. 63) that contains the fabricated Philley citation, Mr. Charles dedicates approximately two pages to arguing that Plaintiff's counsel has a documented history of submitting AI -generated fabricated citations to courts, expressly citin g Jakes v.