ESQ HQNEW YORK LAW WATCH

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 Systems

Holding 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
CourtAppellate Division, First Department
DecidedFebruary 10, 2026
Citation251 AD3d 73
Area of lawAttorney Discipline and Professional Responsibility
WeekWeek ending February 14, 2026
Official textOfficial decision: 251 AD3d 73
Source feedNew York advance sheet: 26nyadv35.pdf
Law Watch record id74

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

Published February 10, 2026. Updated November 14, 2026.