What was the sanction in Mata v. Avianca?

The Southern District of New York imposed a $5,000 sanction and ordered counsel to send corrective letters to the judges named in the fabricated opinions.

Why is Mata v. Avianca important?

It was the first widely reported case of AI-fabricated citations in a court filing, and the court held that lawyers have an affirmative duty to verify every citation before filing, a duty that using an AI tool does not change.

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Mata v. Avianca, Inc.

$5,000

U.S. District Court, S.D.N.Y. (Judge Castel)·2023·The first widely reported AI-hallucination case

Court

U.S. District Court, Southern District of New York (Judge Castel)

Year

2023

Penalty

$5,000, plus an order to send corrective letters to the judges named in the fabricated opinions

What happened

A brief opposing a motion to dismiss cited six non-existent decisions generated by ChatGPT, with fabricated names, citations, and quotations. Asked to confirm, ChatGPT insisted the cases were real.

Primary source

Opinion (Justia) →

Why it still matters

The case that set the rule everyone else was measured against.

Mata v. Avianca is where the duty was stated plainly: attorneys have an affirmative obligation to verify every citation before filing, and reaching for an AI tool does not change it. Every sanction since has turned on the same point. The lesson is not to avoid AI, it is to keep proof that a human checked the output before it left the building.

See how Candor builds that record The $110,204 case →

Common questions

What was the sanction?

A $5,000 penalty, and an order to notify the real judges whose names had been attached to the fabricated opinions.

Why is it a landmark?

It was the first widely reported instance of AI-fabricated citations in a filing, and it established the verification duty that later cases, including the $110,204 Oregon sanction, applied.

This is a reference summary of a publicly reported decision, compiled from the source linked above. It is not legal advice and is not exhaustive. Confirm the details against the primary source. Candor is software, not a law firm.