PC-59 Doe v Jewish Board of Family and Childrens Services Inc
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PC-59 Doe v. The Jewish Board of Family and Children’s Services, Inc. is a New York Supreme Court case in which Justice Sabrina Kraus imposed a $250 sanction on defence counsel on October 28, 2026 for unverified AI-assisted legal submissions.[1]
Submissions and counsel’s explanation
The October 28 decision recounts an October 23 order concerning motion sequence 2. That earlier order identified an incorrect assertion about a private right of action under Social Services Law § 413, a misstatement of the holding in Pelaez v. Seide, and a quotation absent from that decision. It required counsel to explain the submissions by sworn statement.[1]
Counsel’s October 27 affirmation acknowledged using an AI tool without verifying its output, accepted responsibility and apologised. The court stressed lawyers’ responsibility to check factual and legal representations even when generated by software.[1]
October 28, 2026 sanctions order
The court considered counsel’s candour and the apparent first instance of this conduct in setting the sanction at $250. The court applied existing frivolous-conduct and professional-candour standards.[1]
The order requires payment to the Lawyer’s Fund for Client Protection within ten business days and proof of payment on NYSCEF within fifteen days. It separately requires service on the Fund within five business days and an affidavit of service within ten business days. These periods run from the order; payment and compliance have not been verified.[1]