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From Friday’s decision by Judge Sidney Stein (S.D.N.Y.) in Tantaros v. Fox News Network, LLC:
[B]oth Tantaros’s opposition to Brown’s motion to dismiss the complaint and her unauthorized sur-reply contain both inaccurate and non-existent citations to cases and statutes. After Brown’s counsel notified Tantaros of citation issues in her opposition brief, Tantaros filed a “Notice of Correction of Citations” which purported to “immediately withdraw[] voluntarily” some but not all of the non-existent or inaccurate citations in her opposition to Brown’s motion.
Troublingly, Tantaros nevertheless included inaccurate citations in her later-filed sur-reply. This pattern of behavior indicates that Tantaros has used artificial intelligence tools in preparing her filings but did not verify the accuracy of citations produced by those artificial intelligence tools before submitting them to the Court.
Like represented litigants, pro se litigants such as Tantaros have a duty not to submit false citations to the Court. The Court hereby notifies Tantaros that she may be subject to sanctions for any future filings containing inaccurate or non-existent citations….
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