Frustrated by fake citations and flowery prose packed with “out-of-left-field” references to ancient libraries and Ray Bradbury’s Fahrenheit 451, a New York federal judge took the rare step of terminating a case this week due to a lawyer’s repeated misuse of AI when drafting filings. In an order on Thursday, district judge Katherine Polk Failla ruled that the extraordinary sanctions were warranted after an attorney, Steven Feldman, kept responding to requests to correct his filings with documents containing fake citations. One of those filings was “noteworthy,” Failla said, “for its conspicuously florid prose.” Where some of Feldman’s filings contained grammatical errors and run-on sentences, this filing seemed glaringly different stylistically. It featured, the judge noted, “an extended quote from Ray Bradbury’s Fahrenheit 451 and metaphors comparing legal advocacy to gardening and the leaving of indelible ‘mark[s] upon the clay.’” The Bradbury quote is below: “Everyone must leave something behind when he dies, my grandfather said. A child or a book or a painting or a house or a wall built or a pair of shoes made. Or a garden planted. Something your hand touched some way so your soul has somewhere to go when you die, and when people look at that tree or that flower you planted, you’re there. It doesn’t matter what you do, he said, so long as you change something from the way it was before you touched it into something that’s like you after you take your hands away. The difference between the man who just cuts lawns and a real gardener is in the touching, he said. The lawn-cutter might just as well not have been there at all; the gardener will be there a lifetime.” Another passage Failla highlighted as “raising the Court’s eyebrows” curiously invoked a Bible passage about divine judgment as a means of acknowledging the lawyer’s breach of duty in not catching the fake citations:
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