On June 22, 2023, District Judge Hon. P. Kevin Castel of the Southern District of New York issued an unprecedented sanctions order in Mata v. Avianca, No. 22-CV-1461 (PKC), 2023 WL 4114965 (S.D.N.Y. June 22, 2023), arising from counsel's citations to fictional cases fabricated by OpenAI's ChatGPT chatbot.