New York · federal district court · 2025

Pennantia, LLC v. Rose Cay Maritime, LLC

District Court, S.D. New York, 4 September 2025 to 11 September 2025. What the court wrote about citations that did not exist, in its own words, from 2 documents on file.

Case record · S.D.N.Y.

  1. Court. District Court, S.D. New YorkCOURT
  2. Level. federal district courtLEVEL
  3. Dates. 4 September 2025 to 11 September 2025DATED
  4. Docket. No. 1:25-cv-05904DOCKET
  5. Judge. Sidney H. SteinJUDGE
  6. Documents. 2 documents, 10 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 67, 11 September 2025 · source · PDF · 8 pages

Docket text. RESPONSE TO ORDER TO SHOW CAUSE re: 62 Order to Show Cause,,. Document filed by Dove Cay, LLC. (Attachments: # 1 Affidavit Declaration of Patrick F. Lennon, # 2 Affidavit Declaration of Kevin J. Lennon, # 3 Affidavit Declaration of Steven R. Winters, # 4 Affidavit Declaration of Elliott T. Williams).(Lennon, Patrick) (Entered: 09/11/2025)

47), that supported the proposition at issue. The inclusion of the fictitious quotations was inadvertent and occurred without any purpose or intent to mislead the Court or opposing counsel. Undersigned counsel emphasize that there was never any intent to mislead the Court or opposing counsel.

I V. Argument Why Sanctions Should Not Be Imposed While undersigned counsel deeply regret the failure to verify the fictitious quotations generated by the artificial intelligence program used in the initial drafting of the Memorandum, it is respectfully submitted that this lapse does not rise to the level of sanctionable conduct, and is readily distinguishable from the conduct of the attorneys in the cases cited in the Court’s Memorandum Order (ECF No. 62), namely Park v.

In Park, the sanctionable conduct arose from two independent sources of misconduct: (1) the plaintiff’s sustained and willful refusal to comply with discovery orders, which led to dismissal under Rules 37 and 41(b), and (2) counsel’s citation to a wholly non- existent case generated by artificial intelligence, without ever reading or verifying the decision. The Second Circuit stressed that such reliance on fabricated authority constitutes a false statement of law and falls below the basic obligations of counsel. As a sanction, counsel was referred to the court’s grievance panel.

As a sanction, counsel was referred to the court’s grievance panel. By contrast, undersigned counsel in this case did not cite any non-existent case or authority. The cases cited—Crescent Towing and General Electric Credit Corp.—are real Fifth Circuit precedents, long recognized in maritime lien jurisprudence.

The cases cited—Crescent Towing and General Electric Credit Corp.—are real Fifth Circuit precedents, long recognized in maritime lien jurisprudence. The issue here is not the existence of fictitious authorities, but rather the inadvertent and unintentional inclusion of two non -existent quotations generated by an artificial intelligence drafting tool in an early draft, which were not cross-checked against the official opinions during a compressed briefing schedule. The circumstances in Mata are likewise far more serious.

The circumstances in Mata are likewise far more serious. There, counsel relied exclusively on the ChatGPT artificial intelligence to generate not only quotations, but also entire case citations to opinions that did not exist in any reporter or database. Even after opposing counsel specifically advised the court that the cases could not be located, counsel did not withdraw the offending submission.

The court found subjective bad faith based on conscious avoidance, repeated misrepresentations, and the failure to correct known falsehoods, and sanctioned both counsel and their firm . Here, by contrast, no counterfeit opinions were submitted, no effort was made to present fictitious case law as binding precedent, and no false representations were made to the Court. The authorities cited were authentic, and the substantive legal propos ition—that interest may be recovered under a maritime lien—was correct, as confirmed by other authorities relied upon both by the Court and by undersigned counsel.

Hall presents yet another distinct scenario. Counsel in that case filed a brief citing three non-existent cases generated by AI, without confirming their existence in any database. While the court ultimately found negligence rather than bad faith, the submissi on nevertheless rested on fabricated authority.

Docket entry 62, 4 September 2025 · source · PDF · 2 pages

Docket text. MEMORANDUM ORDER: Accordingly, counsel for Dove Cay is Ordered to Show Cause in writing on or before September 11, 2025, why sanctions should not be imposed against Lennon Murphy & Phillips LLC pursuant to Federal Rule of Civil Procedure 11 or the Court's inherent power. Counsel for Pennantia may file any responsive submission on or before September 18, 2025. (And as further set forth herein.) SO ORDERED. Show Cause Response due by 9/11/2025. (Signed by Judge Sidney H. Stein on 9/4/2025) (jca) (Entered: 09/04/2025)

District Judge . 25-cv-5904 (SHS) MEMORANDUM ORDER The Court has reviewed the letter submitted by Lennon Murphy & Phillips LLC, the counsel for Dove Cay, in response to the Court's August 26, 2025 Order regarding non-existent quotations set forth in a memorandum filed by Dove Cay. (Dkt.

As Judge P. Kevin Castel explained when imposing sanctions on an attorney who had submitted non-existent case citations in a submission to the Court, many harms can flow from inaccurate citations in submissions to the Court, including wasting the Court's and opposing parties' time and resources, depriving the attorney's client of potential arguments based on authentic authorities, potentially harming the reputation of the judges and courts whose authority is falsely invoked in support of invalid case citations, and increasing cynicism about the legal profession and judicial system as a whole. Mata v.

What the text mentions

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Where this fits

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More from District Court, S.D. New York, from New York, or from 2025. 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.

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