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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.