Expert: New York Supreme Court, Appellate Division, Second Department, 2026 NY Slip Op 03935, decided June 23, 2026 (Docket 2025-02380) The Appellate Division, Second Department reviewed the plaintiff's appellant's brief in a sidewalk trip-and-fall case and found that it cited to several nonexistent cases, misstated the law, and misrepresented the holdings of real cases. Three of the citations do not exist. 1. "Xiang Fu Ji v City of New York" (13 NY3d 791, 794) - quoted twice for the proposition that Administrative Code section 7-210 should be "construed liberally to effectuate its remedial purpose." The court found that no case by that title exists at all, much less at the citation given. A real case, Xiang Fu He v Troon Mgt., Inc. (34 NY3d 167), analyzes section 7-210, but it does not contain the purported quotation, does not characterize the provision as remedial, and does not instruct that it be construed liberally. The court added that the Court of Appeals has never used the phrase at all - it has held the opposite: section 7-210, being "in derogation of common law, and ... creat[ing] liability where none previously existed, must be strictly construed" (Vucetovic v Epsom Downs, Inc., 10 NY3d 517, 521). 2. "Hausser v Giunta" (88 AD3d 969, 970) - quoted twice as establishing that abutting owners are "in the best position to monitor and control" adjacent walkways. A real case of that name exists (217 AD2d 604, revd 88 NY2d 449), but it arose from an accident in the City of Long Beach and turned on Long Beach City Code section 256 rather than Administrative Code section 7-210, and it does not contain the quoted language. 3. "Lack v Lack" (841 NYS2d 403, 404) - cited for the standard of review on summary judgment. No case by that name appears at that citation, and the court noted there appears never to have been any New York case with that title. The brief also misrepresented real authority: it cited Campaign for Fiscal Equity v State of New York (86 NY2d 307, 318) for how exceptions to remedial statutes should be construed, but that opinion does not use the words "remedial" or "exception" and does not discuss how strictly statutes should be construed; the pin cite refers instead to the standard for pleading sufficiency under CPLR 3211(a)(7). The court imposed a monetary sanction of $8,000 on attorney Michael Sanders and a further $2,500 on his firm, the Law Offices of Michael S. Lamonsoff, PLLC - $10,500 combined - both payable to the Lawyers' Fund for Client Protection of the State of New York within 20 days of service, with proof of payment filed within 10 days, under 22 NYCRR 130-1.1. It declined to award costs because no billing statements were submitted. The court also weighed Sanders's lack of candor at oral argument: he maintained he had found the cases on Westlaw or Lexis, in a book, in a previous case, or in another brief, and declined an offered 15-minute recess to identify them. He later admitted in an affirmation that he "should have stated that they were hallucinated by artificial intelligence" and that he "was genuinely scared at the time." He acknowledged submitting a brief "unknowingly with three fabricated citations," took "full responsibility for the deficiencies identified by the Court," and recalled using AI-assisted research tools but did "not recall which exact tool [he] used, it was one of the free ones available to the public." The court noted that its ruling was limited to sanctions and that the conduct may also be a matter for the Attorney Grievance Committee. Source: https://www.nycourts.gov/reporter/current/3dseries/2026/2026_03935.shtml