# A US federal court fined two attorneys and their firm $5,000 for a brief citing six non-existent cases generated by ChatGPT, noting that using a reliable AI tool is not itself improper

Page: https://flyvolo.ai/en/changes/ev-20230622-lawyer-1
Date: 2023-06-22 · Stage: Constraint
Can this record move a task judgement? yes
Occupation: https://flyvolo.ai/en/careers/lawyer

## Scope

US federal court (S.D.N.Y.). Establishes that the signing lawyer, not the tool, carries responsibility for machine-assisted filings; several bars issued guidance afterwards.

## Source

- Mata v. Avianca, Inc. (S.D.N.Y., 22 June 2023) — opinion and order on sanctions, via CourtListener — https://www.courtlistener.com/docket/63107798/54/mata-v-avianca-inc/ (primary source)

## What this means

A constraint record on the deployment layer that defines the linked task: the court held the signing lawyers, not the tool, responsible for six fabricated citations, and said plainly that using a reliable AI tool is not itself improper. That is the 'supervising machine-assisted work' obligation stated by a court — deciding what the tools may be used for and signing for the output as if you had written it.

## What it does not show yet

A $5,000 sanction in the Southern District of New York is a floor on consequences, not a standard of care; bar guidance issued afterwards varies by jurisdiction and most of it is advisory. The case shows nothing about how well the tools draft when properly checked, and nothing about whether firms hire fewer or more people to do the checking.

## How to verify it yourself

Pull your bar association's most recent guidance on generative AI (most are dated 2023–2025) and compare its verification and disclosure requirements with what your firm's engagement letters and drafting checklist actually say; list every gap, because that gap is where your signature is exposed.


More: https://flyvolo.ai/llms.txt