NY State Bar News

Deutsche Bank v. LeTennier: First NY Appellate AI Citation Sanctions

The NY State Bar analyzes Deutsche Bank Natl. Trust Co. v. LeTennier, New York's first appellate-level decision on sanctions for generative AI misuse. Defense counsel was sanctioned $5,000 for submitting at least 23 fabricated AI-generated cases across five appellate filings, plus an additional $2,500 for counsel and $2,500 for the defendant for pursuing a frivolous appeal. The court held that citing fabricated authority is inherently frivolous under 22 N.Y.C.R.R. 130-1.1(c)(1) and that attorney signature obligations require reasonable inquiry regardless of AI tool use.

NYSBA Celebrates 150th Anniversary and Annual Meeting in New York City

The New York State Bar Association celebrated its 150th anniversary at its 2026 Annual Meeting held at the Hilton Midtown in New York City, drawing thousands of lawyers. The event featured the Constance Baker Motley Symposium honoring Madam C.J. Walker, a Presidential Summit on constitutional failure with Pulitzer Prize historian Jack Rakove and Jan. 6 prosecutor Sonia Mittal, and a Presidential Gala where Governor Kathy Hochul received the Association's Gold Medal. NYSBA also launched 'Rural Ready,' an initiative with the Unified Court System to address New York's legal deserts, and reported that membership increased year over year for the first time in over a decade, with all sections growing at least 10%.

Supreme Court Likely to Decide Academic Freedom Cases

The New York State Bar Association published an article by Seth F. Gilbertson analyzing the constitutional doctrine of academic freedom and predicting that the Supreme Court will likely revisit its Keyishian precedent. The article traces the doctrine's development through three landmark cases—Adler v. Board of Education, Sweezy v. New Hampshire, and Keyishian v. Board of Regents—and argues that contemporary legislative and political pressures on higher education institutions make Supreme Court review increasingly probable.