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Replays · 2d Cir. · January 30, 2024

Park v. Kim

A reply brief cited two court decisions. The Second Circuit could not find one of them and asked for a copy. Counsel could not provide one, and the court referred her to its grievance panel.

Court
U.S. Court of Appeals for the Second Circuit
Decision
Opinion (per curiam), January 30, 2024, 12 pages. Reported at 91 F.4th 610.
Docket
No. 22-2057
The filing
Plaintiff-appellant's reply brief on appeal (Appellant's Reply Br. at 6).
Sanctioned
Plaintiff-appellant's counsel.
Sanction, in the court's words
The court referred counsel "to the Court's Grievance Panel pursuant to Local Rule 46.2 for further investigation" (Opinion (per curiam), p. 11) Counsel was also ordered to give the client a copy of the decision and certify on the docket that she had. There was no fine.
AI tool, as the decision states it
"the artificial intelligence tool ChatGPT" (Opinion (per curiam), p. 3)
Public record
Opinion (per curiam), January 30, 2024; the case on CourtListener.

What the court found

"At the very least, the duties imposed by Rule 11 require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely." (Opinion (per curiam), p. 9)

Counsel's response, the court wrote, showed that "the reason she could not provide a copy of the case is that it does not exist" (Opinion (per curiam), p. 8)

"The brief presents a false statement of law to this Court" (Opinion (per curiam), p. 11)

Each citation the court listed

as filedwhat the court saidwhat the register holds at this citationour default check today
1Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep't 2014)"We were unable to locate the one cited as 'Matter of Bourguignon v. Coordinated Behavioral Health Servs., Inc., 114 A.D.3d 947 (3d Dep't 2014).'" (p. 7)Kay v. Desantis (N.Y. App. Div. 2014)Check this Register holds a different case at this citation: Kay v. Desantis (2014)

1 citations. Run September 24, 2026 with the default check, engine 0.5.0, register data of June 30, 2026: 1 Check this. Each citation was pasted as a line of text (the quoted words first, where we have them) and checked the way the checker checks a draft: no language model, nothing stored. The register column is a direct lookup of the volume and page.

What a check before filing would have shown

One red row: the register holds Kay v. DeSantis at 114 A.D.3d 947, a Third Department decision from 2014, and nothing named Bourguignon.

What this page does not show

  • The court does not say what sits at 114 A.D.3d 947. The register column is our own lookup.
  • Whether a case is still good law. This is not a citator.
  • Anything about the lawyers beyond what the court wrote.

Check your own draft

Paste the draft or upload the PDF. The default check reads every case citation and returns rows like the ones above in a few seconds, with no language model and nothing stored. It is free to try without an account. Then read what the court would read: every case you cite, at the page you cite.

Check a draft before you fileAll replays

Published September 24, 2026, updated September 24, 2026. We read the decision and copied the court's list; if we have misread it, write to hello@proofread.law. The rows are from the run dated above; they can change when the checker does.