Appellate Division, Third Department · January 8, 2026 · 251 AD3d 97
Deutsche Bank v LeTennier
Read the official decision: 251 AD3d 97
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Read the canonical case page at Olympus Legal SystemsHolding The court affirmed the lower court’s orders and imposed monetary sanctions on defense counsel and the defendant for submitting fabricated legal authorities generated by artificial intelligence. The court determined that the submission of hallucinated cases constituted frivolous conduct under 22 NYCRR 130-1.1 and a violation of the Rules of Professional Conduct, warranting sanctions to deter future misconduct.
The court’s words
generative artifcial intelligence (hereinafter GenAI) represents a new paradigm for the legal profession, one which is not inherently improper
251 AD3d 97, at the official text
submission of fabricated legal authorities is completely without merit in law and therefore constitutes frivolous conduct
251 AD3d 97, at the official text
the use of GenAI in no way abrogates an attorney’s or litigant’s obligation to fact check and cite check every document fled with a court
251 AD3d 97, at the official text
we fnd the imposition of a monetary sanction on defense counsel Joshua A. Douglass in the amount of $5,000 to be appropriate
251 AD3d 97, at the official text
| Court | Appellate Division, Third Department |
|---|---|
| Decided | January 8, 2026 |
| Citation | 251 AD3d 97 |
| Area of law | Attorney Discipline and Professional Responsibility · Civil Procedure |
| Week | Week ending January 10, 2026 |
| Official text | Official decision: 251 AD3d 97 |
| Source feed | New York advance sheet: 26nyadv36.pdf |
| Law Watch record id | 78 |
| Caption in the source feed | Deutsche Bank v Letennier |
Recommended citation
ESQ HQ, New York Law Watch, Deutsche Bank v LeTennier, 251 AD3d 97 (Appellate Division, Third Department, January 8, 2026), https://esqhq.com/decisions/251-ad3d-97/
How this record was made
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