Park v. Kim, 91 F.4th 610, 612 (2d Cir. 2024)Counsel openly admits to using ChatGPT after failing to locate desired result with traditional research methods.
Best quote: At the very least, the duties imposed by Rule 11 require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely. Indeed, we can think of no other way to ensure that the arguments made based on those authorities are “warranted by existing law,” Fed. R. Civ. P. 11(b)(2), or otherwise “legally tenable.” Cooter & Gell, 496 U.S. at 393, 110 S.Ct. 2447. As a District Judge of this Circuit recently held when presented with non-existent precedent generated by ChatGPT: “A fake opinion is not ‘existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law. An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Mata v. Avianca, Inc., No. 22CV01461(PKC), ––– F.Supp.3d ––––, ––––, 2023 WL 4114965, at *12 (S.D.N.Y. June 22, 2023).