Appellate Division, First Department · February 10, 2026 · 251 AD3d 73
Matter of Zareh
Read the official decision: 251 AD3d 73
This record is held from search listings because it does not meet the site’s substance floor; the official text is linked below.
Canonical coverage: the full case page for this decision is at Olympus Legal Systems.
ESQ HQ is published by the team behind Aletheia.
Read the canonical case page at Olympus Legal SystemsHolding The court granted the Attorney Grievance Committee’s motion for reciprocal discipline, publicly censuring the respondent for failing to supervise an associate who used AI to draft a brief containing false citations. The court determined that the respondent’s conduct violated New York Rules of Professional Conduct 3.1 and 5.1 by presenting an unreviewed, AI-generated brief and failing to adequately supervise the drafting attorney.
The court’s words
presented to the Court an unreviewed AI-drafted brief, thereby violating Federal Rules of Civil Procedure rule 11 (b)
251 AD3d 73, at the official text
failed to properly supervise the drafting associate on the brief at issue
251 AD3d 73, at the official text
signifcant weight should be given to the sanction imposed by the jurisdiction where the misconduct occurred
251 AD3d 73, at the official text
| Court | Appellate Division, First Department |
|---|---|
| Decided | February 10, 2026 |
| Citation | 251 AD3d 73 |
| Area of law | Attorney Discipline and Professional Responsibility |
| Week | Week ending February 14, 2026 |
| Official text | Official decision: 251 AD3d 73 |
| Source feed | New York advance sheet: 26nyadv35.pdf |
| Law Watch record id | 74 |
Recommended citation
ESQ HQ, New York Law Watch, Matter of Zareh, 251 AD3d 73 (Appellate Division, First Department, February 10, 2026), https://esqhq.com/decisions/251-ad3d-73/
How this record was made
Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.
Read how Law Watch works