ARTIFICIAL INTELLIGENCE [AI] IS NOT USED IN COMPOSING NYPPL SUMMARIES OF JUDICIAL AND QUASI-JUDICIAL DECISIONS.

Nov 15, 2025

Selected items posted on blogs during the week ending November 14, 2025

Data Solutions for Faster Aid Delivery Help eligible individuals gain quick, reliable access to vital services like food and healthcare. Learn More 

Empower Individuals and Families to Achieve Stability and Self-Sufficiency Use Data-Driven Insights to Provide Faster and Easier Access to Vital Social Services. Learn More

ROI You Can Prove: Making the Case for Modern Identity Systems Modern identity systems are critical to secure, digital-first government—but funding them takes a clear business case. This guide walks through a realistic five-year cost-benefit analysis for digital identity systems in the public sector, showing how agencies can forecast ROI, reduce fraud, and accelerate digital transformation. DOWNLOAD

Building Whole-of-State Cybersecurity: A Maturity Model for Shared Resilience This new paper outlines how states can evolve from foundational security practices to advanced, optimized operations — leveraging automation, AI, and shared intelligence to reduce risk and improve response times. DOWNLOAD 

No Wrong Door: Modernizing Digital Identity for Seamless Government Access This paper outlines how a modern IAM strategy — built on single sign-on, multifactor authentication and open standards — reduces complexity, boosts cybersecurity and delivers a better experience for both residents and staff. DOWNLOAD

See How Coordination Brings Connectivity Back After Natural Disasters  Restoring connectivity is essential to recovery. A new docufilm follows broadband crews working alongside utilities and government partners to bring communications back. Watch the Film

No Wrong Door: Modernizing Digital Identity for Seamless Government Access This paper outlines how a modern IAM strategy — built on single sign-on, multifactor authentication and open standards — reduces complexity, boosts cybersecurity and delivers a better experience for both residents and staff. DOWNLOAD

Q&A: Beyond Silos: Optimizing Whole-of-State Defense This Q&A explores how a whole-of-state approach can unify security efforts across departments, while optimizing limited resources.  DOWNLOAD


Nov 14, 2025

New York State Comptroller Thomas P. DiNapoli posts local government and school audits on the Internet

On August 13, 2025, New York State Comptroller Thomas P. DiNapoli posted the following audits on the Internet.

Click the text highlighted in COLOR to access the audit.


Serven Volunteer Fire Company – Board Oversight (Seneca County) The board did not ensure financial activities were properly recorded and reported and resources were adequately safeguarded, which increased the risk that errors or irregularities could occur and remain undetected and uncorrected. The board did not ensure that the bylaws were adequate or enforce their limited financial provisions, establish supplemental financial policies or procedures, conduct a thorough audit of bills or conduct an annual audit of the treasurer’s books and records. The treasurer did not solely receive and deposit all money as required and allowed a member to handle hall rental revenue.


Border City Fire District – Board Oversight (Seneca County) The board did not provide adequate oversight of the district’s financial operations. As a result, the former district fire department chief, who was also a director of the Border City Hose Company, entered into an unauthorized contract with a private corporation and kept an unauthorized bank account into which he inappropriately deposited and withdrew district money. The board did not ensure all goods and services were procured in compliance with state law, district policies or in the best interest of taxpayers. The board did not oversee the chief or ensure the treasurer received, accounted for and dispersed all district money.


Border City Hose Company – Financial Oversight (Seneca County)  Company officers did not provide oversight of company financial operations by performing even the limited oversight responsibilities outlined in the company’s bylaws. Certain officers hindered the treasurer’s ability to perform his fiscal responsibilities by designating themselves as recipients and custodians of most company money. As a result, company money was not always properly accounted for, and a director, who was also the Border City Fire District Fire Department chief, inappropriately used company funds for his personal benefit.


Henderson Fire District – Financial Activities (Jefferson County) The board did not adequately monitor financial activities or ensure the treasurer maintained appropriate records and reports. Auditors determined the treasurer did not prepare accurate and timely bank reconciliations for the general fund checking account and did not reconcile the three interest-bearing savings and money market accounts. The treasurer did not provide the board with a detailed listing of all funds received and disbursed during the month or balance sheet reports. The treasurer also did not file annual financial reports with the State Comptroller’s Office for 2019 through 2024.


Canisteo-Greenwood Central School District – Claims Auditing (Steuben County) The claims auditor did not properly audit all claims prior to payment. Of the 2,943 claims totaling $23.7 million, auditors reviewed 202 claims totaling $1.4 million and determined that 105 claims totaling approximately $804,000 should not have been approved by the claims auditor for payment. While auditors were able to determine that each of the 202 claims was for a proper district purpose, the board had no assurance that claims approved by the claims auditor complied with its written policies and that each purchase was for a proper district purpose.

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Nov 13, 2025

Attorney sanctioned after including AI generated hallucinations in material submitted to the court

New York State Supreme Court Justice Joel M. Cohen introduced his decision in the instant matter as follows: 

"This case adds yet another unfortunate chapter to the story of artificial intelligence misuse in the legal profession. Here, Defendants' counsel not only included an AI-hallucinated citation* and quotations in the summary judgment brief that led to the filing of this motion for sanctions, but also included multiple new AI-hallucinated citations and quotations in Defendants' brief opposing this motion. In other words, counsel relied upon unvetted AI — in his telling, via inadequately supervised colleagues — to defend his use of unvetted AI."

Justice Cohen opined that the use of AI is not the problem per se, "the problem arises when attorneys abdicate their responsibility to ensure their factual and legal representations to the Court—even if originally sourced from AI—are accurate". In the words of the Court, "When attorneys fail to check their work—whether AI-generated or not—they prejudice their clients and do a disservice to the Court and the profession. In sum, counsel's duty of candor to the Court cannot be delegated to a software program".**

Justice Cohen then:

"ORDERED that Plaintiff's motion for sanctions pursuant to 22 NYCRR §130-1.1 is GRANTED, such that Defendants and their counsel are jointly and severally liable to compensate Plaintiff for her reasonable costs and attorney's fees incurred in connection with this motion, together with fees and costs attributable to addressing Defendants' unvetted AI citations and quotations in the summary judgment motion;


"ORDERED that Plaintiff shall submit an application with supporting documentation for the fees awarded above within fourteen (14) days of the date of this order; Defendants and their counsel may submit opposition thereto within fourteen (14) days of Plaintiff's application. Plaintiff shall notify the Court via letter filing on NYSCEF and by email when the application is complete and whether it is opposed or unopposed; and

"ORDERED that Plaintiff's counsel promptly submit a copy of this decision and order to the Grievance Committee for the Appellate Division, First Department and the New Jersey Office of Attorney Ethics, copying defense counsel and this Court on its transmittal letters."

Such "creativity" by an Artificial Intelligence computer program is often referred to as an "AI generated hallucination".

Click HERE to access Justice Cohen's ruling posted on the Internet.


Editor in Chief Harvey Randall served as Director of Personnel, State University of New York Central Administration; Director of Research, Governor's Office of Employee Relations; Principal Attorney, Counsel's Office, New York State Department of Civil Service; and Colonel, JAG, Command Headquarters, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.

CAUTION

Subsequent court and administrative rulings, or changes to laws, rules and regulations may have modified or clarified or vacated or reversed the information and, or, decisions summarized in NYPPL. For example, New York State Department of Civil Service's Advisory Memorandum 24-08 reflects changes required as the result of certain amendments to §72 of the New York State Civil Service Law to take effect January 1, 2025 [See Chapter 306 of the Laws of 2024]. Advisory Memorandum 24-08 in PDF format is posted on the Internet at https://www.cs.ny.gov/ssd/pdf/AM24-08Combined.pdf. Accordingly, the information and case summaries should be Shepardized® or otherwise checked to make certain that the most recent information is being considered by the reader.
THE MATERIAL ON THIS WEBSITE IS FOR INFORMATION ONLY. AGAIN, CHANGES IN LAWS, RULES, REGULATIONS AND NEW COURT AND ADMINISTRATIVE DECISIONS MAY AFFECT THE ACCURACY OF THE INFORMATION PROVIDED IN THIS LAWBLOG. THE MATERIAL PRESENTED IS NOT LEGAL ADVICE AND THE USE OF ANY MATERIAL POSTED ON THIS WEBSITE, OR CORRESPONDENCE CONCERNING SUCH MATERIAL, DOES NOT CREATE AN ATTORNEY-CLIENT RELATIONSHIP.
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